December 31, 2011 by approximately $752 million with a corresponding offset to AOCI, largely attributable to the change from using final average pay to career average pay, which will be amortized as reduction to net periodic benefit cost over the employees’ future service period (approximately 11 years).
Also in December 2011, the Company approved changes to its U. S.  retiree healthcare plans, including changes for certain employees to the contribution subsidy level and eligibility criteria for subsidized retiree medical coverage and the elimination of certain retiree dental coverage, that will reduce Merck’s future costs related to these plans.
These changes reduced the Company’s benefit obligations related to the U. S.  retiree healthcare plans at December 31, 2011 by approximately $150 million with a corresponding offset to AOCI, which will be amortized as reduction to net periodic benefit cost over the employees’ future service period (approximately 11 years).
Savings Plans The Company also maintains defined contribution savings plans in the United States, including plans assumed in connection with the Merger.
The Company matches a percentage of each employee’s contributions consistent with the provisions of the plan for which the employee is eligible.
Total employer contributions to these plans in 2011, 2010 and 2009 were $166 million, $155 million and $111 million, respectively.16.
Other (Income) Expense, Net
## Table 0 ##
The increase in interest income in 2011 as compared with 2010 primarily reflects higher average investment balances.
The decline in interest income and increase in interest expense in 2010 as compared with 2009 is largely attributable to the Merger.
Exchange losses in 2010 reflect $200 million of losses due to two Venezuelan currency devaluations as discussed below.
Other, net (as presented in the table above) in 2011 reflects a $500 million charge related to the resolution of the arbitration proceeding involving the Company’s rights to market Remicade and Simponi (see Note 6), a $136 million gain on the disposition of the Company’s interest in the JJMCP joint venture (see Note 10), and a $127 million gain on the sale of certain manufacturing facilities and related assets (see Note 5).
Other, net in 2010 reflects a $950 million charge for the Vioxx Liability Reserve (see Note 12), and charges related to the settlement of certain pending AWP litigation, partially offset by $443 million of income recognized upon AstraZeneca’s asset option exercise (see Note 10) and $102 million of income recognized on the settlement of certain disputed royalties.
Other, net in 2009 primarily reflects a $7.5 billion gain resulting from recognizing Merck’s previously held equity interest in the MSP Partnership at fair value as a result of obtaining control of the MSP Partnership in the Merger and a $3.2 billion gain on the sale of Merck’s interest in Merial (see Note 10).
As noted above, exchange losses for 2010 reflect losses relating to Venezuelan currency devaluations.
Effective January 11, 2010, the Venezuelan government devalued its currency from at BsF 2.15 per U. S.  dollar to a two-tiered official exchange rate at (1) “the essentials rate” at BsF 2.60 per U. S.  dollar and (2) “the non-essentials rate” at BsF 4.30 per U. S.  dollar.
In January 2010, the Company was required to remeasure its local currency operations in Venezuela to U. S.  dollars as the Venezuelan economy was determined to be hyperinflationary.
Throughout 2010, the Company settled its transactions at the essentials rate and therefore remeasured monetary assets and liabilities utilizing the essentials rate.
In December 2010, the Venezuelan government announced it would eliminate the essentials rate and, effective January 1, 2011, all transactions would be settled at the official rate of at BsF 4.30 per U. S.  dollar.
As a result of this announcement, the Company remeasured its December 31, 2010 monetary assets and liabilities at the new official rate.
Commercial Lending Asset Quality Indicators (a)
## Table 1 ##
(a) Based upon PDs and LGDs.
(b) Pass Rated loans include loans not classified as “Special Mention”, “Substandard”, or “Doubtful”.
(c) Special Mention rated loans have a potential weakness that deserves management’s close attention.
If left uncorrected, these potential weaknesses may result in deterioration of repayment prospects at some future date.
These loans do not expose us to sufficient risk to warrant a more adverse classification at this time.
(d) Substandard rated loans have a well-defined weakness or weaknesses that jeopardize the collection or liquidation of debt.
They are characterized by the distinct possibility that we will sustain some loss if the deficiencies are not corrected.
(e) Doubtful rated loans possess all the inherent weaknesses of a Substandard loan with the additional characteristics that the weakness makes collection or liquidation in full improbable due to existing facts, conditions, and values.
(f) Loans are included above based on their contractual terms as “Pass”, “Special Mention”, “Substandard” or “Doubtful”.
Home Equity and Residential Real Estate Loan Classes We use several credit quality indicators, including delinquency information, nonperforming loan information, updated credit scores, originated and updated LTV ratios, and geography, to monitor and manage credit risk within the home equity and residential real estate loan classes.
We evaluate mortgage loan performance by source originators and loan servicers.
A summary of asset quality indicators follows: Delinquency/Delinquency Rates: We monitor trending of delinquency/delinquency rates for home equity and residential real estate loans.
See the Asset Quality section of this Note 5 for additional information.
Nonperforming Loans: We monitor trending of nonperforming loans for home equity and residential real estate loans.
See the Asset Quality section of this Note 5 for additional information.
Credit Scores: We use a national third-party provider to update FICO credit scores for home equity loans and lines of credit and residential real estate loans on at least a quarterly basis.
The updated scores are incorporated into a series of credit management reports, which are utilized to monitor the risk in the loan classes.
LTV (inclusive of combined loan-to-value (CLTV) ratios for second lien positions): At least annually, we update the property values of real estate collateral and calculate an updated LTV ratio.
For open-end credit lines secured by real estate in regions experiencing significant declines in property values, more frequent valuations may occur.
We examine LTV migration and stratify LTV into categories to monitor the risk in the loan classes.
Historically, we used, and we continue to use, a combination of original LTV and updated LTV for internal risk management reporting and risk management purposes (e. g. , line management, loss mitigation strategies).
In addition to the fact that estimated property values by their nature are estimates, given certain data limitations it is important to note that updated LTVs may be based upon management’s assumptions (e. g. , if an updated LTV is not provided by the third-party service provider, home price index (HPI) changes will be incorporated in arriving at management’s estimate of updated LTV).
Geography: Geographic concentrations are monitored to evaluate and manage exposures.
Loan purchase programs are sensitive to, and focused within, certain regions to manage geographic exposures and associated risks.
There were no options granted in excess of market value in 2011, 2010 or 2009.
Shares of common stock available during the next year for the granting of options and other awards under the Incentive Plans were 33,775,543 at December 31, 2011.
Total shares of PNC common stock authorized for future issuance under equity compensation plans totaled 35,304,422 shares at December 31, 2011, which includes shares available for issuance under the Incentive Plans and the Employee Stock Purchase Plan (ESPP) as described below.
During 2011, we issued 731,336 shares from treasury stock in connection with stock option exercise activity.
As with past exercise activity, we currently intend to utilize primarily treasury stock for any future stock option exercises.
Awards granted to non-employee directors in 2011, 2010 and 2009 include 27,090, 29,040, and 39,552 deferred stock units, respectively, awarded under the Outside Directors Deferred Stock Unit Plan.
A deferred stock unit is a phantom share of our common stock, which requires liability accounting treatment until such awards are paid to the participants as cash.
As there are no vesting or service requirements on these awards, total compensation expense is recognized in full on awarded deferred stock units on the date of grant.
INCENTIVE/PERFORMANCE UNIT SHARE AWARDS AND RESTRICTED STOCK/UNIT AWARDS The fair value of nonvested incentive/performance unit share awards and restricted stock/unit awards is initially determined based on prices not less than the market value of our common stock price on the date of grant.
The value of certain incentive/ performance unit share awards is subsequently remeasured based on the achievement of one or more financial and other performance goals generally over a three-year period.
The Personnel and Compensation Committee of the Board of Directors approves the final award payout with respect to incentive/performance unit share awards.
Restricted stock/unit awards have various vesting periods generally ranging from 36 months to 60 months.
Beginning in 2011, we incorporated two changes to certain awards under our existing long-term incentive compensation programs.
First, for certain grants of incentive performance units, the future payout amount will be subject to a negative annual adjustment if PNC fails to meet certain risk-related performance metrics.
This adjustment is in addition to the existing financial performance metrics relative to our peers.
These grants have a three-year performance period and are payable in either stock or a combination of stock and cash.
Second, performance-based restricted share units (performance RSUs) were granted in 2011 to certain of our executives in lieu of stock options.
These performance RSUs (which are payable solely in stock) have a service condition, an internal risk-related performance condition, and an external market condition.
Satisfaction of the performance condition is based on four independent one-year performance periods.
The weighted-average grant-date fair value of incentive/ performance unit share awards and restricted stock/unit awards granted in 2011, 2010 and 2009 was $63.25, $54.59 and $41.16 per share, respectively.
We recognize compensation expense for such awards ratably over the corresponding vesting and/or performance periods for each type of program.
Nonvested Incentive/Performance Unit Share Awards and Restricted Stock/Unit Awards – Rollforward
## Table 2 ##
In the chart above, the unit shares and related weightedaverage grant-date fair value of the incentive/performance awards exclude the effect of dividends on the underlying shares, as those dividends will be paid in cash.
At December 31, 2011, there was $61 million of unrecognized deferred compensation expense related to nonvested sharebased compensation arrangements granted under the Incentive Plans.
This cost is expected to be recognized as expense over a period of no longer than five years.
The total fair value of incentive/performance unit share and restricted stock/unit awards vested during 2011, 2010 and 2009 was approximately $52 million, $39 million and $47 million, respectively.
LIABILITY AWARDS We grant annually cash-payable restricted share units to certain executives.
The grants were made primarily as part of an annual bonus incentive deferral plan.
While there are timebased and service-related vesting criteria, there are no market or performance criteria associated with these awards.
Compensation expense recognized related to these awards was recorded in prior periods as part of annual cash bonus criteria.
As of December 31, 2011, there were 753,203 of these cashpayable restricted share units outstanding.

<table><tr><td><i>Years Ended December 31</i></td><td>2011</td><td>2010</td><td>2009</td></tr><tr><td>Interest income</td><td>$-199</td><td>$-83</td><td>$-210</td></tr><tr><td>Interest expense</td><td>749</td><td>715</td><td>460</td></tr><tr><td>Exchange losses (gains)</td><td>143</td><td>214</td><td>-12</td></tr><tr><td>Other, net</td><td>253</td><td>458</td><td>-10,906</td></tr><tr><td></td><td>$946</td><td>$1,304</td><td>$-10,668</td></tr></table>
<table><tr><td></td><td></td><td colspan="3">Criticized Commercial Loans</td><td></td></tr><tr><td>In millions</td><td>PassRated (b)</td><td>Special Mention (c)</td><td>Substandard (d)</td><td>Doubtful (e)</td><td>Total Loans</td></tr><tr><td> December 31, 2011</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Commercial</td><td>$60,649</td><td>$1,831</td><td>$2,817</td><td>$257</td><td>$65,554</td></tr><tr><td>Commercial real estate</td><td>11,478</td><td>791</td><td>2,823</td><td>400</td><td>15,492</td></tr><tr><td>Equipment lease financing</td><td>6,210</td><td>48</td><td>153</td><td>5</td><td>6,416</td></tr><tr><td>Purchased impaired loans</td><td>107</td><td>35</td><td>542</td><td>168</td><td>852</td></tr><tr><td>Total commercial lending (f)</td><td>$78,444</td><td>$2,705</td><td>$6,335</td><td>$830</td><td>$88,314</td></tr><tr><td>December 31, 2010</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Commercial</td><td>$48,556</td><td>$1,926</td><td>$3,883</td><td>$563</td><td>$54,928</td></tr><tr><td>Commercial real estate</td><td>11,014</td><td>1,289</td><td>3,914</td><td>564</td><td>16,781</td></tr><tr><td>Equipment lease financing</td><td>6,121</td><td>64</td><td>162</td><td>46</td><td>6,393</td></tr><tr><td>Purchased impaired loans</td><td>106</td><td>35</td><td>883</td><td>378</td><td>1,402</td></tr><tr><td>Total commercial lending (f)</td><td>$65,797</td><td>$3,314</td><td>$8,842</td><td>$1,551</td><td>$79,504</td></tr></table>
<table><tr><td>Shares in thousands</td><td>Nonvested Incentive/ Performance Unit Shares</td><td>Weighted- Average Grant Date Fair Value</td><td>Nonvested Restricted Stock/ Unit Shares</td><td>Weighted- Average Grant Date Fair Value</td></tr><tr><td>December 31, 2010</td><td>363</td><td>$56.40</td><td>2,250</td><td>$49.95</td></tr><tr><td>Granted</td><td>623</td><td>64.21</td><td>1,059</td><td>62.68</td></tr><tr><td>Vested</td><td>-156</td><td>59.54</td><td>-706</td><td>51.27</td></tr><tr><td>Forfeited</td><td></td><td></td><td>-91</td><td>52.24</td></tr><tr><td>December 31, 2011</td><td>830</td><td>$61.68</td><td>2,512</td><td>$54.87</td></tr></table>

Question: What's the average of PassRated (b) in 2011? (in million)
Answer: 19611