SSA Benefit Estimate Statement: Adding Rate of Return Information May Not
Be Appropriate (Letter Report, 09/02/98, GAO/HEHS-98-228).
Pursuant to a congressional request, GAO reviewed the recent proposal
that would require the Social Security Administration (SSA) to place on
the Personal Earnings and Benefit Estimate Statements (PEBES) an
individualized estimate of the rates of return workers receive on their
contributions to the Social Security program, focusing on the: (1)
general implications of using a rate of return for social security; and
(2) challenges of including this information on the PEBES.
GAO noted that: (1) there is substantial disagreement about whether the
rate of return concept should be applied to the Social Security program;
(2) supporters of such an application point out that a rate of return
would provide individuals information about the return they receive on
their contributions to the program; (3) however, others contend that it
is inappropriate to use rate of return estimates for social security
because the program is designed to pursue social insurance goals, such
as ensuring that low-wage earners have adequate income in their old age
or that dependent survivors are adequately provided for; (4) in
addition, calculations for rates of return rely on a number of
assumptions that affect the resulting estimates; (5) for individuals,
the actual rates of return can vary substantially from the estimates due
to various uncertainties, such as a worker's actual retirement age and
future earnings; (6) to be clearly understood, the underlying
assumptions and their effect on the estimates should be explained in any
presentation of rate of return information; (7) furthermore, comparing
rate of return estimates for social security with estimates for private
investments could be difficult for various reasons; (8) for example, the
comparisons would need to indicate whether the estimates for other
investments include the transaction and administrative costs and the
differences in risk associated with the social security trust funds and
private investments; (9) providing rate of return information on the
PEBES could further complicate and lengthen an already complex and
difficult-to-understand statement; (10) in GAO's previous work, it
concluded that the current PEBES is too long and its explanations of
social security's complex programs are not easy for the public to
understand; and (11) adding rate of return estimates to the PEBES would
require detailed explanations about how the calculations were made and
what assumptions were used about comparing a rate of return for social
security with rates for private investments.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: HEHS-98-228
TITLE: SSA Benefit Estimate Statement: Adding Rate of Return
Information May Not Be Appropriate
DATE: 09/02/98
SUBJECT: Social security benefits
Federal social security programs
Disability benefits
Comparative analysis
Investment planning
Retirement benefits
Written communication
IDENTIFIER: Social Security Disability Insurance Program
Social Security Program
Old Age Survivors and Disability Insurance Program
SSA Personal Earnings and Benefits Estimate Statement
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Cover
================================================================ COVER
Report to Congressional Requesters
September 1998
SSA BENEFIT ESTIMATE STATEMENT -
ADDING RATE OF RETURN INFORMATION
MAY NOT BE APPROPRIATE
GAO/HEHS-98-228
SSA Benefit Estimate Statement
(207020)
Abbreviations
=============================================================== ABBREV
DI - Disability Insurance
OASI - Old Age and Survivors Insurance
PEBES - Personal Earnings and Benefit Estimate Statement
SSA - Social Security Administration
Letter
=============================================================== LETTER
B-280622
September 2, 1998
The Honorable Jim Bunning
Chairman, Subcommittee on Social Security
Committee on Ways and Means
House of Representatives
The Honorable William V. Roth, Jr.
Chairman
The Honorable Daniel P. Moynihan
Ranking Minority Member
Committee on Finance
United States Senate
To provide the public with information about the Social Security
program, the Congress enacted a law that requires the Social Security
Administration (SSA) to provide to individuals regular statements
that estimate the benefits they may receive through the program.\1 In
1995, SSA began sending Personal Earnings and Benefit Estimate
Statements (PEBES) automatically to workers who had reached age 60.
Starting in fiscal year 2000, the PEBES will be sent annually to
almost every U.S. worker aged 25 and older--an estimated 123 million
people each year. These six-page statements provide workers with a
list of their yearly earnings on record at SSA, information about
their eligibility for benefits, and estimates of these benefits.
(The 1998 PEBES is reprinted in app. I.)
Recently, in the course of the debate regarding how to restore
long-term solvency for the Social Security program, legislation has
been proposed that would require SSA to place on the PEBES an
individualized estimate of the rates of return workers receive on
their contributions to the Social Security program. The purpose of
the proposal is, in part, to provide information that would enable
workers to compare the current Social Security program with other
investments, including alternatives being discussed in the reform
debate.
In light of this proposal, you asked us to look at (1) the general
implications of using a rate of return for Social Security and (2)
the challenges of including this information on the PEBES. To
respond to your request, we relied on our ongoing work on calculating
and using rates of return, which includes an extensive review of the
literature on this issue, and our prior work on the usefulness of the
PEBES.\2 In addition, we obtained relevant information from SSA
officials and other experts. We conducted our work in June and July
1998 in accordance with generally accepted government auditing
standards. In our ongoing work on rates of return, we will more
fully address the extent to which Social Security and private market
rates of return can be compared.
--------------------
\1 P.L. 101-239 and P.L. 101-508.
\2 SSA Benefit Statements: Well Received by the Public but Difficult
to Comprehend (GAO/HEHS-97-19, Dec. 5, 1996).
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
There is substantial disagreement about whether the rate of return
concept should be applied to the Social Security program. Supporters
of such an application point out that a rate of return would provide
individuals information about the return they receive on their
contributions to the program. However, others contend that it is
inappropriate to use rate of return estimates for Social Security
because the program is designed to pursue social insurance goals,
such as ensuring that low-wage earners have adequate income in their
old age or that dependent survivors are adequately provided for. In
addition, calculations for rates of return rely on a number of
assumptions that affect the resulting estimates. For individuals,
the actual rates of return can vary substantially from the estimates
due to various uncertainties, such as a worker's actual retirement
age and future earnings. To be clearly understood, the underlying
assumptions and their effect on the estimates should be explained in
any presentation of rate of return information. Furthermore,
comparing rate of return estimates for Social Security with estimates
for private investments could be difficult for various reasons. For
example, the comparisons would need to indicate whether the estimates
for other investments include the transaction and administrative
costs and the differences in risk associated with the Social Security
trust funds and private investments.
Providing rate of return information on the PEBES could further
complicate and lengthen an already complex and
difficult-to-understand statement. In our previous work, we
concluded that the current PEBES is too long and its explanations of
Social Security's complex programs are not easy for the public to
understand. Adding rate of return estimates to the PEBES would
require detailed explanations about how the calculations were made
and what assumptions were used about the individual. In addition,
SSA would need to caution PEBES recipients about comparing a rate of
return for Social Security with rates for private investments.
BACKGROUND
------------------------------------------------------------ Letter :2
PEBES legislation required SSA to begin sending benefit estimate
statements to workers aged 60 and older in fiscal year 1995 and to
those turning 60 during each fiscal year from 1996 through 1999;
starting in fiscal year 2000, SSA must send the PEBES annually to
almost every worker aged 25 and older.\3 However, to better manage
the expected workload, SSA officials are sending the PEBES to many
workers ahead of schedule. As a result, most workers aged 40 and
older--about 65 million--will have received their first statement by
the end of 1998.
The PEBES was conceived as a means to inform the public about the
benefits available under the Old Age and Survivors Insurance (OASI)
and the Disability Insurance (DI) programs, which together are
commonly known as "Social Security." These programs provide monthly
cash benefits to retired and disabled workers and their dependents
and survivors. The benefit amounts are based primarily on a worker's
earnings. By providing individual workers with a listing of their
yearly earnings on record at SSA and estimates of the benefits they
may receive, SSA hopes to better ensure that its earnings records are
complete and accurate and to assist workers in planning for their
financial future.
As a result of profound demographic changes--such as the aging of the
baby boom generation and increasing life expectancy--Social
Security's yearly expenditures are expected to exceed its yearly tax
revenue beginning in 2013. Without corrective legislation, the trust
funds are expected to be depleted by 2032, leaving insufficient funds
to pay the current level of benefits. As a result of the financial
problems facing the program, a national debate on how to ensure
Social Security's solvency has begun and will likely intensify.
Ensuring long-term solvency within the current program structure will
require either increasing revenues or reducing expenditures, or some
combination of both. This could be achieved through a variety of
methods, such as raising the retirement age, reducing inflation
adjustments, increasing payroll taxes, and investing trust fund
reserves in securities with potentially higher yields than the U.S.
Treasury securities currently held by the trust funds.
Some options for change, however, would fundamentally alter the
program structure by setting up individual retirement savings
accounts managed by the government or personal security accounts
managed through the private sector. Both of these options would
permit investments in potentially higher yielding securities.
Proponents of adding rates of return to the PEBES believe these rates
would provide individuals with information on the current program and
enable them to compare their rate of return for Social Security with
rates for other investments.
--------------------
\3 SSA must send a PEBES to those who are at least 25 years old, have
a Social Security number, have wages or net earnings from
self-employment, are not receiving Social Security benefits, and have
a current address obtainable by SSA.
USING RATE OF RETURN ESTIMATES
FOR SOCIAL SECURITY POSES
CHALLENGES
------------------------------------------------------------ Letter :3
Analysts disagree about whether it is appropriate to use rates of
return to evaluate the Social Security program and the options for
reform. Furthermore, using rates of return for Social Security
presents a number of difficulties. Estimates would be based on a
variety of assumptions, such as how long the worker is expected to
live after retirement, and other decisions, such as whether to
include disability benefits. These uncertainties and how they affect
individual rates of return would need to be explained. Also,
comparing rates of return for Social Security with rates for private
market investments presents a variety of difficulties, such as how to
handle transaction costs and the differences in the level of risk,
which also need to be accounted for in the comparison.
Social Security contributions are mostly used to pay benefits to
current beneficiaries and are not deposited in interest-bearing
accounts for individual workers. In fact, benefit payments to any
given individual are derived from a formula that does not use
interest rates or the amount of contributions. Still, the benefits
workers will eventually receive reflect a rate of return they
implicitly receive on their contributions. This rate of return is
equal to the average interest rate workers would have to receive on
their contributions in order to pay for all the benefits they will
receive from Social Security.\4
--------------------
\4 A more technically precise definition of the rate of return for
Social Security contributions would be the constant discount rate
that equates the present discounted value of contributions with the
present discounted value of benefits.
ANALYSTS DISAGREE ON USING A
RATE OF RETURN FOR SOCIAL
SECURITY
---------------------------------------------------------- Letter :3.1
As part of the Social Security reform debate, some analysts contend
that comparing rates of return for Social Security with rates for the
private market will help individuals understand that they could have
potentially higher retirement incomes with a new system of individual
retirement savings accounts. Moreover, they believe that the new
system would produce real additions to national saving. In turn, new
saving would generate economic and productivity growth that yields
real returns to society and to consumers. They assert that Social
Security, in contrast, only transfers income from taxpayers to
beneficiaries, detracts from saving and long-term economic growth,
and produces no real economic returns.
Other analysts, however, contend that the rate of return concept
should not be applied to Social Security for various reasons. First,
they observe that Social Security is a social insurance program that
helps protect workers and retirees against a variety of risks over
which they often have little control, such as the performance of the
economy and inflation. For example, the Social Security program is
designed to help ensure that low-wage earners have adequate income in
their retirement. Second, some analysts observe that Social Security
simply transfers money from taxpayers to beneficiaries and is not
designed to provide returns on contributions. Third, some analysts
believe that the full value of the program cannot be determined
solely by comparing monetary benefits and contributions. For
example, individuals benefit from Social Security in other, more
general ways through reductions in poverty and being relieved of
providing for their parents and other beneficiaries through some
other means.
RATE OF RETURN ESTIMATES FOR
INDIVIDUALS ARE UNCERTAIN
AND REQUIRE EXPLANATION
---------------------------------------------------------- Letter :3.2
Rate of return estimates will vary according to what contributions
and benefits they include. Moreover, actual rates of return for
individuals will differ substantially from estimates due to the
uncertainty of several factors, such as how long they will live, how
much they will earn, and what size families they will have. To be
clearly understood, rate of return estimates for Social Security need
an explanation of how they are calculated and how uncertain the
estimates are.
DECIDING WHICH
CONTRIBUTIONS AND
BENEFITS TO INCLUDE
-------------------------------------------------------- Letter :3.2.1
Estimates of rates of return on contributions need to be clear about
which benefits are included. For example, Social Security provides
benefit payments to many individuals other than retired workers. In
1996, retired workers accounted for 61 percent of all Social Security
beneficiaries, and they received 68 percent of the benefits. Other
beneficiaries include disabled workers, survivors of deceased
workers, and spouses and children of retired and disabled workers.
If the calculations include the full range of benefits provided by
the Social Security program, rather than retirement benefits alone,
then the calculations would also need to include the full range of
contributions made for those benefits. Conversely, if the
calculations include only the retirement portion of the benefits,
then the contributions would need to be reduced accordingly.
Social Security contributions are made by employers as well as
employees. Currently, both the individual and the employer pay a 6.2
percent tax on covered earnings for OASI and DI combined.\5 Most rate
of return estimates prepared by analysts include both the employer
and employee shares; however, some analysts believe the employer
contributions should not be included. Analysts using both employer
and employee contributions argue that employees ultimately pay the
employer share because employers pay lower wages than they would if
the employer contribution did not exist. Furthermore, estimates that
leave out the employer contributions reflect the full benefits but
not the full costs of providing those benefits.
A number of other issues affect benefits, contributions, or both and
would need to be disclosed with the rate of return estimate. For
example, Social Security benefits are automatically adjusted for
inflation. In addition, even if the disability benefits and
corresponding contributions are not included in the return estimates,
OASI benefits provided for families of workers who die before
retirement should be included. Finally, how much individuals
contribute and how much they receive in benefits depend on when they
retire and whether they continue to work while receiving benefits;
this could be addressed by assuming a standard retirement age.
--------------------
\5 Self-employed workers pay a contribution rate of 12.4 percent,
half of which is tax deductible as a business expense.
FACTORS CONTRIBUTING TO
UNCERTAINTY OF ESTIMATES
-------------------------------------------------------- Letter :3.2.2
Many factors that would be included in rate of return estimates for
Social Security are subject to considerable uncertainty, and these
uncertainties mean that the actual rates of return that individuals
receive could vary substantially from their estimates. Such factors
include how long individuals will live, how much they will earn in
the future, whether their contributions will also entitle their
spouses or children to benefits, and what changes the Congress may
make to contribution and benefit levels. These uncertainties suggest
that individual estimates would be very rough and might best be
described as a range of rates. The literature examining rates of
return almost always discusses them in the context of the reform
debate and, therefore, examines average rates for large groups of
people with similar characteristics, such as birth year, income
level, and gender. Such average group rates can be estimated with a
reasonable degree of accuracy and precision, but an individual's
actual experience may be dramatically different.
Rate of return estimates depend fundamentally on individual earnings
histories, which are used to project workers' future earnings,
calculate their benefits, and estimate the amount of their
contributions. Because rate of return estimates for Social Security
rely on projected earnings, they are inherently uncertain. In
addition, younger workers' rates of return would be even more
uncertain since they have more years for which earnings need to be
projected.
Under the current program structure, rate of return estimates would
also need to reflect additional benefits provided by workers'
contributions. Their contributions not only entitle workers to
retirement benefits but also entitle their spouses and children to
survivor and dependent benefits. However, SSA's records do not
include information on whether a worker has a spouse or children
unless and until such dependents apply for benefits based on the
worker's record. Moreover, neither SSA nor the workers can be
certain who will have spouses, children, or survivors who might
collect benefits based on the workers' earnings records and how long
their dependents will collect these benefits.
In addition, in many families, both the husband and wife work and one
may be "dually entitled" to benefits based on both workers' records.
Individuals are entitled to receive either a benefit based on their
own earnings or a benefit equal to 50 percent of the benefit
calculated from their spouse's record, whichever is greater. As a
result of this benefit option, a dually entitled couple's rate of
return on their contributions is generally different than their
individual rates. However, SSA has no way to connect a working
couple's two individual earnings records until one applies for
benefits based on the other's records.
FACTORS TO CONSIDER WHEN
COMPARING RATES OF RETURN
FOR SOCIAL SECURITY AND
PRIVATE MARKET INVESTMENTS
---------------------------------------------------------- Letter :3.3
While some analysts have sought to compare rate of return estimates
for Social Security with rates of return for private market
investments--such as stocks, bonds, or savings accounts--these
comparisons are not as straightforward as they first appear.
Explanations would be needed to understand a number of important
factors, including whether the rates of return incorporated the
transaction and administrative costs for investments or annuities,
the differences in risk associated with Social Security and private
investments, and the questions of how to treat the costs of the
benefits promised under the current system when switching to any
other retirement system.
Under typical Social Security privatization proposals, individual
retirement savings accounts would offer workers the potential to
receive higher rates of return on private investments than their
Social Security contributions implicitly receive. However, private
investments would entail a variety of transaction and administrative
costs of their own, and these would vary depending on the nature of
the proposal. For example, stockbrokers charge commissions for
making trades, and mutual fund managers are compensated for managing
the funds. Reflected in such costs are marketing and advertising
expenses incurred as money managers and brokers compete for
investors' business. In contrast, SSA does not maintain actual
accounts for each individual but rather keeps records of earnings.
Administrative costs for Social Security's OASI program are less than
1 percent of annual program revenues. Accurate rate of return
comparisons would need to look at the rates after adjusting for
expenses.
Accurate rate of return comparisons also need to take into account
the differences in risk associated with those rates. Over long
periods of time, riskier private market investments, such as stocks,
on average earn higher rates of return than less risky ones, such as
government bonds. The riskier the investment, the greater the
variation in possible investment earnings. By the same token, the
riskier the investment made with retirement savings, the greater the
variation in possible retirement incomes.
Finally, if rates of return for Social Security are compared with
rates for alternative reform proposals, the comparisons should
indicate whether the rates for the alternatives take into account the
costs of the benefits promised under the current Social Security
program. Any rate of return comparisons should include these
transition costs and not be limited to the return on private
investments.
PRESENTING RATE OF RETURN
INFORMATION WOULD COMPLICATE
PEBES
------------------------------------------------------------ Letter :4
The PEBES aims to provide information about the complex programs and
benefits available through the Social Security program; however, the
current statement is already lengthy and difficult to understand.
Adding a rate of return, along with the corresponding narrative that
would be needed to understand all of the underlying assumptions and
uncertainties, would further complicate PEBES' message. In addition,
placing rate of return information on the statement would add
significantly to SSA's workload, according to SSA officials.
CURRENT PEBES DOES NOT
COMMUNICATE CLEARLY
---------------------------------------------------------- Letter :4.1
Although the PEBES is intended to be a tool for communicating with
the public, we raised concerns about the usefulness of the statement
in a 1996 report.\6 We reported that although the public feels the
statement can be a valuable tool for retirement planning, the current
PEBES provides too much information and fails to communicate clearly
the information its readers need to understand SSA's current programs
and benefits.\7
Comments from SSA's public focus groups, SSA employees, and benefit
experts indicate that the statement contains too much information.
For example, SSA reported in a 1994 focus group summary that younger
workers aged 25 to 35 wanted a more simplified, one-page statement
with their estimated benefits and contributions. In addition, SSA
telephone representatives said that they believe most people calling
in with questions have read only the section of the statement that
provides the benefit estimates.
Since the PEBES addresses complex programs and issues, explaining
these points in straightforward language can be challenging.
Although SSA officials told us they attempt to use simple language
geared for a seventh-grade reading level, feedback from the public
and SSA staff indicates that readers are confused by several
important explanations. For example, the public frequently asks
about PEBES' explanation of family benefits. Family benefits are
difficult to calculate and explain because the amounts are based on
information from both spouses' records and SSA does not maintain
information that links individuals' records with those of their
spouses. In addition, many people ask for clarification on certain
terms used in the statement and on how their benefit estimates are
calculated.
Based on our recommendation, SSA is working on simplifying the PEBES.
Agency officials are currently testing four alternative versions of
the statement, and they plan to use the redesigned version of the
PEBES for the fiscal year 2000 mailings.
--------------------
\6 GAO/HEHS-97-19, Dec. 5, 1996.
\7 We reviewed the 1996 statement; however, the 1998 statement has
the same format and contains identical narrative, except for the
opening message from the Commissioner of Social Security.
RATE OF RETURN INFORMATION
WOULD FURTHER COMPLICATE
PEBES
---------------------------------------------------------- Letter :4.2
For rate of return information on the PEBES to be understood, SSA
would need to (1) decide how much information to provide and (2)
explain it in simple straightforward language--language that could be
easily understood by the diverse population of workers slated to
receive the statement. SSA would first need to define rate of return
and explain that individuals' rates could vary substantially from the
estimates. In addition, readers would need to be cautioned that
changes in the Social Security program due to long-term financing
problems could affect their rates of return. Furthermore, SSA would
need to explain the factors included in the calculation and all the
underlying assumptions and uncertainties. As discussed previously,
these would include
-- the amounts that were used for the worker's future earnings,
-- whether the estimate includes the disability contributions and
potential benefits,
-- whether employer's contributions were included along with the
worker's,
-- the worker's expected retirement age,
-- the worker's life expectancy after retirement, and
-- how the estimate would vary if the worker's spouse or children
qualify for benefits on the worker's record.
The PEBES currently addresses how the benefit estimates treat some of
these factors--future earnings, retirement ages, and family benefits.
However, rate of return estimates are even more sensitive to these
issues than benefit estimates; therefore, they would require further
explanation. For example, the PEBES currently explains that the
worker's future earnings are projected to remain the same as the
latest earnings on record. A rate of return estimate based on a
steady level of earnings would be different from one in which the
earnings vary. In addition, since the PEBES provides benefit
estimates at three retirement ages, the statement would need to
explain which of the three ages was used for the individual's rate of
return estimate. Finally, the statement's complicated discussion of
family benefits, which explains that the amount of these benefits is
dependent on the worker's benefit and the number of people in the
family who would receive benefits, would need to be expanded. The
explanation would need to indicate whether the individual's rate of
return estimate incorporates any family benefits and what effect
family benefits would have on the individual's rate of return.
Along with the explanations needed for the rate of return itself,
PEBES recipients would need to be cautioned regarding the limitations
of comparing a rate of return on Social Security with rates for
alternative investments. Before making comparisons, recipients would
need to know that the rate of return presented on their PEBES may
need to be adjusted for other factors. As discussed earlier, these
factors would include
-- the difference in administrative costs of the alternative
investments,
-- the difference in the level of risk associated with the
alternative investments, and
-- how the costs of the benefits promised under the current program
are treated.
Furthermore, according to SSA, placing rate of return information on
the PEBES would add significantly to workloads across the agency.
For example, officials stated that they would expect the volume of
calls about the rate of return information to dramatically increase
their workload. Staff would need training to be prepared to respond
to inquiries regarding the individual rates of return as well as how
the rates compare with those for other investments. In addition, SSA
officials said significantly changing the PEBES would be difficult to
do in a timely manner. If individualized rates of return were to be
added, SSA would need time to prepare the calculation, develop the
explanations that would be needed to accompany the rates, test the
new statement, make programming changes, and renegotiate the PEBES
printing and mailing contract.
CONCLUSION
------------------------------------------------------------ Letter :5
Given the disagreement over whether it is appropriate to apply the
rate of return concept to the Social Security program and the number
of assumptions that must be factored into such an estimate, it would
be especially important to fully explain how the rate was calculated
and how uncertain the estimate could be. However, it has already
been difficult to develop a PEBES that provides readily
understandable information on the existing programs and benefits
alone. Adding rate of return information could significantly
increase the statement's length and undermine SSA's current efforts
to shorten and simplify it. Given the detailed explanations that
would be needed along with the estimates, adding rate of return
information to the PEBES would most likely complicate an already
complex statement.
AGENCY COMMENTS
------------------------------------------------------------ Letter :6
We obtained comments on a draft of this report from SSA. SSA agreed
with our overall conclusions and said the report reflects the
difficulties the agency would face in placing understandable rate of
return information on the PEBES. In addition, SSA pointed out that
it is working hard to make the information currently provided in the
PEBES easy for readers to understand and use and agreed that adding
rate of return information would increase the complexity of the
statement. Finally, SSA provided technical comments, which we
incorporated in this report where appropriate. SSA's general and
technical comments are reprinted in appendix II.
---------------------------------------------------------- Letter :6.1
We are sending copies of this report to the Commissioner of Social
Security. Copies will also be made available to others on request.
If you or your staff have any questions concerning this report,
please call me or Kay E. Brown, Assistant Director, on (202)
512-7125. Other major contributors to this report include R.
Elizabeth Jones, Evaluator-in-Charge, and Kenneth C. Stockbridge,
Senior Evaluator.
Barbara D. Bovbjerg
Associate Director, Income Security Issues
(See figure in printed edition.)Appendix I
PERSONAL EARNINGS AND BENEFIT
ESTIMATE STATEMENT
============================================================== Letter
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)Appendix II
COMMENTS FROM THE SOCIAL SECURITY
ADMINISTRATION
============================================================== Letter
(See figure in printed edition.)
*** End of document. ***