MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS NON-GAAP FINANCIAL MEASURES TABLE 3: NON-GAAP FINANCIAL MEASURES  RECENT ACCOUNTING STANDARDS The Bancorp considers various measures when evaluating capital  utilization and adequacy, including the tangible equity ratio,  tangible common equity ratio and tier I common equity ratio, in  addition to capital ratios defined by banking regulators. These  calculations are intended to complement the capital ratios defined  by banking regulators for both absolute and comparative  purposes. Because U.S. GAAP does not include capital ratio  measures, the Bancorp believes there are no comparable U.S.  GAAP financial measures to these ratios. Tier I common equity is  not formally defined by U.S. GAAP or codified in the federal  banking regulations and, therefore, is considered to be a non- GAAP financial measure. Since analysts and banking regulators  may assess the Bancorp’s capital adequacy using these ratios, the  Bancorp believes they are useful to provide investors the ability to  assess its capital adequacy on the same basis.  The Bancorp believes these non-GAAP measures are  important because they reflect the level of capital available to  withstand unexpected market conditions. Additionally, presentation of these measures allows readers to compare certain  aspects of the Bancorp’s capitalization to other organizations.  However, because there are no standardized definitions for these  ratios, the Bancorp’s calculations may not be comparable with  other organizations, and the usefulness of these measures to  investors may be limited. As a result, the Bancorp encourages  readers to consider its Consolidated Financial Statements in their  entirety and not to rely on any single financial measure. The following table reconciles non-GAAP financial measures  to U.S. GAAP as of December 31:  Note 1 of the Notes to Consolidated Financial Statements  provides a discussion of the significant new accounting standards  adopted by the Bancorp during 2010 and 2009 and the expected  impact of significant accounting standards issued, but not yet  required to be adopted.  (a) Under the banking agencies’ risk-based capital guidelines, assets and credit equivalent amounts of derivatives and off-balance sheet exposures are assigned to broad risk categories. The aggregate  dollar amount in each risk category is multiplied by the associated risk weight of the category. The resulting weighted values are added together, resulting in the Bancorp’s total risk-weighted assets.  ($ in millions)  2010  2009  Total Bancorp shareholders’ equity (U.S. GAAP)  $14,051  $13,497 Less:  Goodwill  (2,417)  (2,417) Intangible assets  (62)  (106) Accumulated other comprehensive income  (314)  (241) Tangible equity (1)  11,258  10,733 Less: preferred stock  (3,654)  (3,609) Tangible common equity (2)  7,604  7,124 Total assets (U.S. GAAP)  111,007  113,380 Less:  Goodwill (2,417)  (2,417) Intangible assets  (62)  (106) Accumulated other comprehensive income, before tax  (483)  (370) Tangible assets, excluding unrealized gains / losses (3)  $108,045  $110,487 Total Bancorp shareholders’ equity (U.S. GAAP)  14,051  $13,497 Goodwill and certain other intangibles  (2,546)  (2,565) Unrealized gains  (314)  (241) Qualifying trust preferred securities  2,763  2,763 Other  11  (26) Tier I capital  13,965  13,428 Less: Preferred stock  (3,654)  (3,609) Qualifying trust preferred securities  (2,763)  (2,763) Qualified noncontrolling interest in consolidated subsidiaries  (30)  - Tier I common equity (4)  7,518  7,056 Risk-weighted assets (5) ( a )  100,193  100,933 Ratios:  Tangible equity (1) / (3)  10.42%  9.71% Tangible common equity (2) / (3)  7.04%  6.45% Tier I common equity (4) / (5)  7.50%  6.99% Fifth Third Bancorp 19 