Table 55 Allowance for Credit Losses (continued)
## Table 0 ##
(5) Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option.
Loans accounted for under the fair value option were $8.8 billion and $3.3 billion at December 31, 2011 and 2010.
Average loans accounted for under the fair value option were $8.4 billion and $4.1 billion in 2011 and 2010.
(6) Excludes consumer loans accounted for under the fair value option of $2.2 billion at December 31, 2011.
There were no consumer loans accounted for under the fair value option at December 31, 2010.
(7) Excludes commercial loans accounted for under the fair value option of $6.6 billion and $3.3 billion at December 31, 2011 and 2010.
(8) For more information on our definition of nonperforming loans, see pages 86 and 94.
(9) Primarily includes amounts allocated to Card Services portfolios, PCI loans and the non-U.
S.  credit portfolio in All Other.
For reporting purposes, we allocate the allowance for credit losses across products.
However, the allowance is available to absorb any credit losses without restriction.
Table 56 presents our allocation by product type.
## Table 1 ##
(1) Ratios are calculated as allowance for loan and lease losses as a percentage of loans and leases outstanding excluding loans accounted for under the fair value option.
Consumer loans accounted for under the fair value option included residential mortgage loans of $906 million and discontinued real estate of $1.3 billion at December 31, 2011.
There were no consumer loans accounted for under the fair value option at December 31, 2010.
Commercial loans accounted for under the fair value option included U. S.  commercial loans of $2.2 billion and $1.6 billion, non-U.
S.  commercial loans of $4.4 billion and $1.7 billion and commercial real estate loans of $0 and $79 million at December 31, 2011 and 2010.
(2) Includes allowance for U. S.  small business commercial loans of $893 million and $1.5 billion at December 31, 2011 and 2010.
(3) Includes allowance for loan and lease losses for impaired commercial loans of $545 million and $1.1 billion at December 31, 2011 and 2010.
(4) Includes $8.5 billion and $6.4 billion of valuation reserves presented with the allowance for credit losses related to PCI loans at December 31, 2011 and 2010.
Collateralized Debt Obligation and Monoline Exposure CDO vehicles hold diversified pools of fixed-income securities and issue multiple tranches of debt securities including commercial paper, and mezzanine and equity securities.
Our CDO-related exposure can be divided into funded and unfunded super senior liquidity commitment exposure and other super senior exposure, including cash positions and derivative contracts.
For more information on our CDO positions, see Note 8 – Securitizations and Other Variable Interest Entities to the Consolidated Financial Statements.
Super senior exposure represents the most senior class of notes that are issued by the CDO vehicles and benefits from the subordination of all other securities issued by the CDO vehicles.
In 2011, we recorded losses of $86 million from our CDO-related exposure compared to losses of $573 million in 2010.
At December 31, 2011, our super senior CDO exposure before consideration of insurance, net of write-downs, was $376 million, comprised solely of trading account assets, compared to $2.0 billion, comprised of $1.3 billion in trading account assets and $675 million in AFS debt securities at December 31, 2010.
Of our super senior CDO exposure at December 31, 2011, $224 million was hedged and $152 million was unhedged compared to $772 million hedged and $1.2 billion unhedged at December 31, 2010.
At December 31, 2011, there were no unrealized losses recorded in accumulated other comprehensive income (OCI) on super senior cash positions and retained positions from liquidated CDOs compared to $466 million at December 31, 2010.
The change was the result of sales of ABS CDOs.
With the Merrill Lynch acquisition, we acquired a loan that is collateralized by U. S.  super senior ABS CDOs and recorded in All Other.
For additional information, see All Other on page 48.
Excluding amounts related to transactions with a single counterparty, which were transferred to other assets as discussed below, the table below presents our original total notional, markto-market receivable and credit valuation adjustment for credit default swaps (CDS) and other positions with monolines.
## Table 2 ##
Total monoline exposure, net of credit valuation adjustments, decreased $2.6 billion to $1.3 billion at December 31, 2011 driven by terminated monoline contracts and the reclassification of certain exposures.
During 2011, we terminated all of our monoline contracts referencing super senior ABS CDOs and reclassified net monoline exposure with a carrying value of $1.3 billion ($4.7 billion gross receivable less impairment) at December 31, 2011 from derivative assets to other assets because of the inherent default risk.
Because these contracts no longer provide a hedge benefit, they are no longer considered derivative trading instruments.
This exposure relates to a single counterparty and is recorded at fair value based on current net recovery projections.
The net recovery projections take into account the present value of projected payments expected to be received from the counterparty.
Bank of America, N. A.  and FIA Card Services, N. A.
Regulatory Capital Table 15 presents regulatory capital information for BANA and FIA at December 31, 2011 and 2010.
## Table 3 ##
BANA’s Tier 1 capital ratio increased 96 bps to 11.74 percent and the Total capital ratio increased 91 bps to 15.17 percent at December 31, 2011 compared to 2010.
The increase in the ratios was driven by $9.6 billion in earnings generated during 2011.
The Tier 1 leverage ratio increased 82 bps to 8.65 percent, benefiting from the improvement in Tier 1 capital combined with a $73.4 billion decrease in adjusted quarterly average total assets resulting from our continued efforts to reduce non-core assets and legacy loan portfolios.
FIA’s Tier 1 capital ratio increased 233 bps to 17.63 percent and the Total capital ratio increased 207 bps to 19.01 percent at December 31, 2011 compared to 2010.
The Tier 1 leverage ratio increased 101 bps to 14.22 percent at December 31, 2011 compared to 2010.
The increase in ratios was driven by $5.7 billion in earnings generated during 2011 and a reduction in risk-weighted assets.
During 2011, BANA paid dividends of $9.8 billion to Bank of America Corporation.
FIA returned capital of $7.0 billion to Bank of America Corporation during 2011 and is anticipated to return an additional $3.0 billion in 2012.
Broker/Dealer Regulatory Capital The Corporation’s principal U. S.  broker/dealer subsidiaries are Merrill Lynch, Pierce, Fenner & Smith (MLPF&S) and Merrill Lynch Professional Clearing Corp (MLPCC).
MLPCC is a fully-guaranteed subsidiary of MLPF&S and provides clearing and settlement services.
Both entities are subject to the net capital requirements of SEC Rule 15c3-1.
Both entities are also registered as futures commission merchants and are subject to the CFTC Regulation 1.17.
MLPF&S has elected to compute the minimum capital requirement in accordance with the Alternative Net Capital Requirement as permitted by SEC Rule 15c3-1.
At December 31, 2011, MLPF&S’s regulatory net capital as defined by Rule 15c3-1 was $10.8 billion and exceeded the minimum requirement of $803 million by $10.0 billion.
MLPCC’s net capital of $3.5 billion exceeded the minimum requirement of $168 million by approximately $3.3 billion.
In accordance with the Alternative Net Capital Requirements, MLPF&S is required to maintain tentative net capital in excess of $1 billion, net capital in excess of $500 million and notify the SEC in the event its tentative net capital is less than $5 billion.
At December 31, 2011, MLPF&S had tentative net capital and net capital in excess of the minimum and notification requirements.
Economic Capital Our economic capital measurement process provides a risk-based measurement of the capital required for unexpected credit, market and operational losses over a one-year time horizon at a 99.97 percent confidence level.
Economic capital is allocated to each business unit based upon its risk positions and contribution to enterprise risk, and is used for capital adequacy, performance measurement and risk management purposes.
The strategic planning process utilizes economic capital with the goal of allocating risk appropriately and measuring returns consistently across all businesses and activities.
Economic capital allocation plans are incorporated into the Corporation’s financial plan which is approved by the Board on an annual basis.
Credit Risk Capital Economic capital for credit risk captures two types of risks: default risk, which represents the loss of principal due to outright default or the borrower’s inability to repay an obligation in full, and migration risk, which represents potential loss in market value due to credit deterioration over the one-year capital time horizon.
Credit risk is assessed and modeled for all on- and off-balance sheet credit exposures within sub-categories for commercial, retail, counterparty and investment securities.
The economic capital methodology captures dimensions such as concentration and country risk and originated securitizations.
The economic capital methodology is based on the probability of default, loss given default (LGD), exposure at default (EAD) and maturity for each credit exposure, and the portfolio correlations across exposures.
See page 74 for more information on Credit Risk Management.
Five-Year Performance Comparison – The following graph provides an indicator of cumulative total shareholder returns for the Corporation as compared to the peer group index (described above), the DJ Trans, and the S&P 500.
The graph assumes that $100 was invested in the common stock of Union Pacific Corporation and each index on December 31, 2006 and that all dividends were reinvested.

<table><tr><td>Table 55</td><td>Allowance for Credit Losses (continued)</td><td></td><td></td></tr><tr><td colspan="2">(Dollars in millions)</td><td>2011</td><td>2010</td></tr><tr><td colspan="2">Loan and allowance ratios:</td><td></td><td></td></tr><tr><td colspan="2">Loans and leases outstanding at December 31<sup>-5</sup></td><td>$917,396</td><td>$937,119</td></tr><tr><td colspan="2">Allowance for loan and lease losses as a percentage of total loans and leases and outstanding at December 31<sup>-5</sup></td><td>3.68%</td><td>4.47%</td></tr><tr><td colspan="2">Consumer allowance for loan and lease losses as a percentage of total consumer loans outstanding at December 31<sup>-6</sup></td><td>4.88</td><td>5.40</td></tr><tr><td colspan="2">Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31<sup>-7</sup></td><td>1.33</td><td>2.44</td></tr><tr><td colspan="2">Average loans and leases outstanding<sup>-5</sup></td><td>$929,661</td><td>$954,278</td></tr><tr><td colspan="2">Net charge-offs as a percentage of average loans and leases outstanding<sup>-5</sup></td><td>2.24%</td><td>3.60%</td></tr><tr><td colspan="2">Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31<sup>-5, 8</sup></td><td>135</td><td>136</td></tr><tr><td colspan="2">Ratio of the allowance for loan and lease losses at December 31 to net charge-offs</td><td>1.62</td><td>1.22</td></tr><tr><td colspan="2">Amounts included in allowance for loan and lease losses that are excluded from nonperforming loans and leases at December 31<sup>-9</sup></td><td>$17,490</td><td>$22,908</td></tr><tr><td colspan="2">Allowance for loan and lease losses as a percentage of total nonperforming loans and leases excluding amounts included in the allowance for loan and lease losses that are excluded from nonperforming loans and leases at December 31<sup>-9</sup></td><td>65%</td><td>62%</td></tr><tr><td colspan="2">Loan and allowance ratios excluding purchased credit-impaired loans:</td><td></td><td></td></tr><tr><td colspan="2">Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31<sup>-5</sup></td><td>2.86%</td><td>3.94%</td></tr><tr><td colspan="2">Consumer allowance for loan and lease losses as a percentage of total consumer loans outstanding at December 31<sup>-6</sup></td><td>3.68</td><td>4.66</td></tr><tr><td colspan="2">Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31<sup>-7</sup></td><td>1.33</td><td>2.44</td></tr><tr><td colspan="2">Net charge-offs as a percentage of average loans and leases outstanding<sup>-5</sup></td><td>2.32</td><td>3.73</td></tr><tr><td colspan="2">Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31<sup>-5, 8</sup></td><td>101</td><td>116</td></tr><tr><td colspan="2">Ratio of the allowance for loan and lease losses at December 31 to net charge-offs</td><td>1.22</td><td>1.04</td></tr></table>
<table><tr><td>Table 56</td><td colspan="6">Allocation of the Allowance for Credit Losses by Product Type</td></tr><tr><td></td><td colspan="3">December 31, 2011</td><td colspan="3">December 31, 2010</td></tr><tr><td>(Dollars in millions)</td><td>Amount</td><td>Percent ofTotal</td><td>Percent ofLoans andLeasesOutstanding<sup>-1</sup></td><td>Amount</td><td>Percent ofTotal</td><td>Percent ofLoans andLeasesOutstanding<sup>-1</sup></td></tr><tr><td>Allowance for loan and lease losses</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Residential mortgage</td><td>$5,935</td><td>17.57%</td><td>2.26%</td><td>$5,082</td><td>12.14%</td><td>1.97%</td></tr><tr><td>Home equity</td><td>13,094</td><td>38.76</td><td>10.50</td><td>12,887</td><td>30.77</td><td>9.34</td></tr><tr><td>Discontinued real estate</td><td>2,050</td><td>6.07</td><td>18.48</td><td>1,283</td><td>3.06</td><td>9.79</td></tr><tr><td>U.S. credit card</td><td>6,322</td><td>18.71</td><td>6.18</td><td>10,876</td><td>25.97</td><td>9.56</td></tr><tr><td>Non-U.S. credit card</td><td>946</td><td>2.80</td><td>6.56</td><td>2,045</td><td>4.88</td><td>7.45</td></tr><tr><td>Direct/Indirect consumer</td><td>1,153</td><td>3.41</td><td>1.29</td><td>2,381</td><td>5.68</td><td>2.64</td></tr><tr><td>Other consumer</td><td>148</td><td>0.44</td><td>5.50</td><td>161</td><td>0.38</td><td>5.67</td></tr><tr><td>Total consumer</td><td>29,648</td><td>87.76</td><td>4.88</td><td>34,715</td><td>82.88</td><td>5.40</td></tr><tr><td>U.S. commercial<sup>-2</sup></td><td>2,441</td><td>7.23</td><td>1.26</td><td>3,576</td><td>8.54</td><td>1.88</td></tr><tr><td>Commercial real estate</td><td>1,349</td><td>3.99</td><td>3.41</td><td>3,137</td><td>7.49</td><td>6.35</td></tr><tr><td>Commercial lease financing</td><td>92</td><td>0.27</td><td>0.42</td><td>126</td><td>0.30</td><td>0.57</td></tr><tr><td>Non-U.S. commercial</td><td>253</td><td>0.75</td><td>0.46</td><td>331</td><td>0.79</td><td>1.03</td></tr><tr><td>Total commercial<sup>-3</sup></td><td>4,135</td><td>12.24</td><td>1.33</td><td>7,170</td><td>17.12</td><td>2.44</td></tr><tr><td>Allowance for loan and lease losses</td><td>33,783</td><td>100.00%</td><td>3.68</td><td>41,885</td><td>100.00%</td><td>4.47</td></tr><tr><td>Reserve for unfunded lending commitments</td><td>714</td><td></td><td></td><td>1,188</td><td></td><td></td></tr><tr><td>Allowance for credit losses<sup>-4</sup></td><td>$34,497</td><td></td><td></td><td>$43,073</td><td></td><td></td></tr></table>
<table><tr><td></td><td colspan="2">December 31</td></tr><tr><td>(Dollars in millions)</td><td>2011</td><td>2010</td></tr><tr><td>Notional</td><td>$21,070</td><td>$38,424</td></tr><tr><td>Mark-to-market or guarantor receivable</td><td>$1,766</td><td>$9,201</td></tr><tr><td>Credit valuation adjustment</td><td>-417</td><td>-5,275</td></tr><tr><td>Total</td><td>$1,349</td><td>$3,926</td></tr><tr><td>Credit valuation adjustment %</td><td>24%</td><td>57%</td></tr><tr><td>Gains (losses)</td><td>$116</td><td>$-24</td></tr></table>
<table><tr><td>Table 15</td><td colspan="2">Bank of America, N.A. and FIA Card Services, N.A. Regulatory Capital</td><td colspan="2"></td></tr><tr><td></td><td colspan="4">December 31</td></tr><tr><td></td><td colspan="2">2011</td><td colspan="2">2010</td></tr><tr><td>(Dollars in millions)</td><td>Ratio</td><td>Amount</td><td>Ratio</td><td>Amount</td></tr><tr><td>Tier 1</td><td></td><td></td><td></td><td></td></tr><tr><td>Bank of America, N.A.</td><td>11.74%</td><td>$119,881</td><td>10.78%</td><td>$114,345</td></tr><tr><td>FIA Card Services, N.A.</td><td>17.63</td><td>24,660</td><td>15.30</td><td>25,589</td></tr><tr><td>Total</td><td></td><td></td><td></td><td></td></tr><tr><td>Bank of America, N.A.</td><td>15.17</td><td>154,885</td><td>14.26</td><td>151,255</td></tr><tr><td>FIA Card Services, N.A.</td><td>19.01</td><td>26,594</td><td>16.94</td><td>28,343</td></tr><tr><td>Tier 1 leverage</td><td></td><td></td><td></td><td></td></tr><tr><td>Bank of America, N.A.</td><td>8.65</td><td>119,881</td><td>7.83</td><td>114,345</td></tr><tr><td>FIA Card Services, N.A.</td><td>14.22</td><td>24,660</td><td>13.21</td><td>25,589</td></tr></table>

Question: What's the average of Amounts included in allowance for loan and lease losses that are excluded from nonperforming loans and leases in 2011and 2010? (in million)
Answer: 20199