A Bank has the following balance sheet (in millions), with the risk weights in parentheses.

Assets					Liabilities and Equity
Cash (0%)	$	19				Deposits	$	171
Mortgage loans (50%)	$	65				Subordinate debt (>5 years)	$	8
Consumer loans (100%)	$	115				Equity	$	16
Reserve for loan losses	($	4	)
Total Assets	$	195				Total Liability and Equity	$	195

In addition, the bank has $30 million in commercial direct-credit substitute standby letters of credit to a public corporation and $30 million in 10-year FX forward contracts that are in the money by $2 million. What is the Tier I risk-based capital ratio?

6.50%

8.85%

10.85%

12.50%

None of the above