THE GOLDMAN SACHS GROUP, INC.  AND SUBSIDIARIES Management’s Discussion and Analysis 2018 versus 2017.
Provision for credit losses in the consolidated statements of earnings was $674 million for 2018, compared with $657 million for 2017, as the higher provision for credit losses primarily related to consumer loan growth in 2018 was partially offset by an impairment of approximately $130 million on a secured loan in 2017.2017 versus 2016.
Provision for credit losses in the consolidated statements of earnings was $657 million for 2017, compared with $182 million for 2016, reflecting an increase in impairments, which included an impairment of approximately $130 million on a secured loan in 2017, and higher provision for credit losses primarily related to consumer loan growth.
Operating Expenses Our operating expenses are primarily influenced by compensation, headcount and levels of business activity.
Compensation and benefits includes salaries, discretionary compensation, amortization of equity awards and other items such as benefits.
Discretionary compensation is significantly impacted by, among other factors, the level of net revenues, overall financial performance, prevailing labor markets, business mix, the structure of our share-based compensation programs and the external environment.
In addition, see “Use of Estimates” for further information about expenses that may arise from litigation and regulatory proceedings.
The table below presents operating expenses by line item and headcount.
## Table 0 ##
In the table above, the following reclassifications have been made to previously reported amounts to conform to the current presentation: ‰ Regulatory-related fees that are paid to exchanges are now reported in brokerage, clearing, exchange and distribution fees.
Previously such amounts were reported in other expenses.
‰ Headcount consists of our employees, and excludes consultants and temporary staff previously reported as part of total staff.
As a result, expenses related to these consultants and temporary staff are now reported in professional fees.
Previously such amounts were reported in compensation and benefits expenses.2018 versus 2017.
Operating expenses in the consolidated statements of earnings were $23.46 billion for 2018, 12% higher than 2017.
Our efficiency ratio (total operating expenses divided by total net revenues) for 2018 was 64.1%, compared with 64.0% for 2017.
The increase in operating expenses compared with 2017 was primarily due to higher compensation and benefits expenses, reflecting improved operating performance, and significantly higher net provisions for litigation and regulatory proceedings.
Brokerage, clearing, exchange and distribution fees were also higher, reflecting an increase in activity levels, and technology expenses increased, reflecting higher expenses related to computing services.
In addition, expenses related to consolidated investments and our digital lending and deposit platform increased, with the increases primarily in depreciation and amortization expenses, market development expenses and other expenses.
The increase compared with 2017 also included $297 million related to the recently adopted revenue recognition standard.
See Note 3 to the consolidated financial statements for further information about ASU No.2014-09, “Revenue from Contracts with Customers (Topic 606).
” Net provisions for litigation and regulatory proceedings for 2018 were $844 million compared with $188 million for 2017.2018 included a $132 million charitable contribution to Goldman Sachs Gives, our donor-advised fund.
Compensation was reduced to fund this charitable contribution to Goldman Sachs Gives.
We ask our participating managing directors to make recommendations regarding potential charitable recipients for this contribution.
As of December 2018, headcount increased 9% compared with December 2017, reflecting an increase in technology professionals and investments in new business initiatives.2017 versus 2016.
Operating expenses in the consolidated statements of earnings were $20.94 billion for 2017, 3% higher than 2016.
Our efficiency ratio for 2017 was 64.0% compared with 65.9% for 2016.
The increase in operating expenses compared with 2016 was primarily driven by slightly higher compensation and benefits expenses and our investments to fund growth.
Higher expenses related to consolidated investments and our digital lending and deposit platform were primarily included in depreciation and amortization expenses, market development expenses and other expenses.
In addition, technology expenses increased, reflecting higher expenses related to cloud-based services and software depreciation, and professional fees increased, primarily related to consulting costs.
These increases were partially offset by lower net provisions for litigation and regulatory proceedings, and lower occupancy expenses (primarily related to exit costs in 2016).
Note 26 – Regulatory capital The Federal Reserve establishes capital requirements, including well-capitalized standards, for the consolidated financial holding company.
The OCC establishes similar minimum capital requirements and standards for the Firm’s IDI, including JPMorgan Chase Bank, N. A.  and Chase Bank USA, N. A.
Capital rules under Basel III establish minimum capital ratios and overall capital adequacy standards for large and internationally active U. S.  bank holding companies and banks, including the Firm and its IDI subsidiaries.
Basel III set forth two comprehensive approaches for calculating RWA: a standardized approach (“Basel III Standardized”) and an advanced approach (“Basel III Advanced”).
Certain of the requirements of Basel III are subject to phase-in periods that began on January 1, 2014 and continue through the end of 2018 (“transitional period”).
The three categories of risk-based capital and their predominant components under the Basel III Transitional rules are illustrated below:
## Table 1 ##
The following tables present the regulatory capital, assets and risk-based capital ratios for JPMorgan Chase and its significant IDI subsidiaries under both Basel III Standardized Transitional and Basel III Advanced Transitional at December 31, 2017 and 2016.
## Table 2 ##
Notes to consolidated financial statements Securities lending indemnifications Through the Firm’s securities lending program, counterparties’ securities, via custodial and non-custodial arrangements, may be lent to third parties.
As part of this program, the Firm provides an indemnification in the lending agreements which protects the lender against the failure of the borrower to return the lent securities.
To minimize its liability under these indemnification agreements, the Firm obtains cash or other highly liquid collateral with a market value exceeding 100% of the value of the securities on loan from the borrower.
Collateral is marked to market daily to help assure that collateralization is adequate.
Additional collateral is called from the borrower if a shortfall exists, or collateral may be released to the borrower in the event of overcollateralization.
If a borrower defaults, the Firm would use the collateral held to purchase replacement securities in the market or to credit the lending client or counterparty with the cash equivalent thereof.
Derivatives qualifying as guarantees The Firm transacts certain derivative contracts that have the characteristics of a guarantee under U. S.  GAAP.
These contracts include written put options that require the Firm to purchase assets upon exercise by the option holder at a specified price by a specified date in the future.
The Firm may enter into written put option contracts in order to meet client needs, or for other trading purposes.
The terms of written put options are typically five years or less.
Derivatives deemed to be guarantees also includes stable value contracts, commonly referred to as “stable value products”, that require the Firm to make a payment of the difference between the market value and the book value of a counterparty’s reference portfolio of assets in the event that market value is less than book value and certain other conditions have been met.
Stable value products are transacted in order to allow investors to realize investment returns with less volatility than an unprotected portfolio.
These contracts are typically longer-term or may have no stated maturity, but allow the Firm to elect to terminate the contract under certain conditions.
The notional value of derivatives guarantees generally represents the Firm’s maximum exposure.
However, exposure to certain stable value products is contractually limited to a substantially lower percentage of the notional amount.
The fair value of derivative guarantees reflects the probability, in the Firm’s view, of whether the Firm will be required to perform under the contract.
The Firm reduces exposures to these contracts by entering into offsetting transactions, or by entering into contracts that hedge the market risk related to the derivative guarantees.
The following table summarizes the derivatives qualifying as guarantees as of December 31, 2017, and 2016.

<table><tr><td></td><td>Year Ended December</td></tr><tr><td><i>$ in millions</i></td><td>2018</td><td>2017</td><td>2016</td></tr><tr><td>Compensation and benefits</td><td>$12,328</td><td>$11,653</td><td>$11,448</td></tr><tr><td>Brokerage, clearing, exchange and distribution fees</td><td>3,200</td><td>2,876</td><td>2,823</td></tr><tr><td>Market development</td><td>740</td><td>588</td><td>457</td></tr><tr><td>Communications and technology</td><td>1,023</td><td>897</td><td>809</td></tr><tr><td>Depreciation and amortization</td><td>1,328</td><td>1,152</td><td>998</td></tr><tr><td>Occupancy</td><td>809</td><td>733</td><td>788</td></tr><tr><td>Professional fees</td><td>1,214</td><td>1,165</td><td>1,081</td></tr><tr><td>Other expenses</td><td>2,819</td><td>1,877</td><td>1,900</td></tr><tr><td>Total operating expenses</td><td>$23,461</td><td>$20,941</td><td>$20,304</td></tr><tr><td>Headcount atperiod-end</td><td>36,600</td><td>33,600</td><td>32,400</td></tr></table>
<table><tr><td></td><td colspan="5">JPMorgan Chase & Co.</td></tr><tr><td></td><td colspan="2">Basel III Standardized Transitional</td><td></td><td colspan="2">Basel III Advanced Transitional</td></tr><tr><td>(in millions,except ratios)</td><td>Dec 31, 2017</td><td>Dec 31, 2016</td><td></td><td>Dec 31, 2017</td><td>Dec 31,2016</td></tr><tr><td>Regulatory capital</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>CET1 capital</td><td>$183,300</td><td>$182,967</td><td></td><td>$183,300</td><td>$182,967</td></tr><tr><td>Tier 1 capital<sup>(a)</sup></td><td>208,644</td><td>208,112</td><td></td><td>208,644</td><td>208,112</td></tr><tr><td>Total capital</td><td>238,395</td><td>239,553</td><td></td><td>227,933</td><td>228,592</td></tr><tr><td>Assets</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Risk-weighted</td><td>1,499,506</td><td>1,483,132</td><td><sup>(e)</sup></td><td>1,435,825</td><td>1,476,915</td></tr><tr><td>Adjusted average<sup>(b)</sup></td><td>2,514,270</td><td>2,484,631</td><td></td><td>2,514,270</td><td>2,484,631</td></tr><tr><td>Capital ratios<sup>(c)</sup></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>CET1</td><td>12.2%</td><td>12.3%</td><td><sup>(e)</sup></td><td>12.8%</td><td>12.4%</td></tr><tr><td>Tier 1<sup>(a)</sup></td><td>13.9</td><td>14.0</td><td><sup>(e)</sup></td><td>14.5</td><td>14.1</td></tr><tr><td>Total</td><td>15.9</td><td>16.2</td><td><sup>(e)</sup></td><td>15.9</td><td>15.5</td></tr><tr><td>Tier 1 leverage<sup>(d)</sup></td><td>8.3</td><td>8.4</td><td></td><td>8.3</td><td>8.4</td></tr></table>
<table><tr><td></td><td colspan="5">JPMorgan Chase Bank, N.A.</td></tr><tr><td></td><td colspan="2">Basel III Standardized Transitional</td><td></td><td colspan="2">Basel III Advanced Transitional</td></tr><tr><td>(in millions,except ratios)</td><td>Dec 31, 2017</td><td>Dec 31, 2016</td><td></td><td>Dec 31, 2017</td><td>Dec 31,2016</td></tr><tr><td>Regulatory capital</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>CET1 capital</td><td>$184,375</td><td>$179,319</td><td></td><td>$184,375</td><td>$179,319</td></tr><tr><td>Tier 1 capital<sup>(a)</sup></td><td>184,375</td><td>179,341</td><td></td><td>184,375</td><td>179,341</td></tr><tr><td>Total capital</td><td>195,839</td><td>191,662</td><td></td><td>189,419</td><td>184,637</td></tr><tr><td>Assets</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Risk-weighted</td><td>1,335,809</td><td>1,311,240</td><td><sup>(e)</sup></td><td>1,226,534</td><td>1,262,613</td></tr><tr><td>Adjusted average<sup>(b)</sup></td><td>2,116,031</td><td>2,088,851</td><td></td><td>2,116,031</td><td>2,088,851</td></tr><tr><td>Capital ratios<sup>(c)</sup></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>CET1</td><td>13.8%</td><td>13.7%</td><td><sup>(e)</sup></td><td>15.0%</td><td>14.2%</td></tr><tr><td>Tier 1<sup>(a)</sup></td><td>13.8</td><td>13.7</td><td><sup>(e)</sup></td><td>15.0</td><td>14.2</td></tr><tr><td>Total</td><td>14.7</td><td>14.6</td><td><sup>(e)</sup></td><td>15.4</td><td>14.6</td></tr><tr><td>Tier 1 leverage<sup>(d)</sup></td><td>8.7</td><td>8.6</td><td></td><td>8.7</td><td>8.6</td></tr></table>

Question: What is the sum of the Tier 1 capital in the years where CET1 capital greater for Basel III Standardized Transitional is greater than 18300? (in million)
Answer: 417288