oversight

Financial Literacy: Enhancing the Effectiveness of the Federal Government's Role

Published by the Government Accountability Office on 2012-04-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                            United States Government Accountability Office

GAO                         Testimony
                            Before the Subcommittee on Oversight of
                            Government Management, the Federal Workforce,
                            and the District of Columbia, Committee on
                            Homeland Security and Governmental Affairs,
                            U.S. Senate

                            FINANCIAL LITERACY
For Release on Delivery
Expected at 2:30 p.m. EDT
Thursday, April 26, 2012



                            Enhancing the
                            Effectiveness of the Federal
                            Government’s Role
                            Statement of Alicia Puente Cackley, Director
                            Financial Markets and Community Investment




GAO-12-636T
                                              April 26, 2012

                                              FINANCIAL LITERACY
                                              Enhancing the Effectiveness of the Federal
                                              Government’s Role
Highlights of GAO-12-636T, a testimony
before the Subcommittee on Oversight of
Government Management, the Federal
Workforce, and the District of Columbia,
Committee on Homeland Security and
Governmental Affairs, U.S. Senate

Why GAO Did This Study                        What GAO Found
Financial literacy plays an important         The federal government plays a wide-ranging role in promoting financial literacy.
role in helping to promote the financial      Efforts to improve financial literacy in the United States involve an array of public,
health and stability of individuals and       nonprofit, and private participants, but among those participants, the federal
families. Economic changes in recent          government is distinctive for its size and reach and for the diversity of its
years have further highlighted the need       components, which address a wide range of issues and populations. At forums of
to empower all Americans to make              financial literacy experts that GAO held in 2004 and 2011, participants noted that
informed financial decisions. In              the federal government can use its “bully pulpit,” convening power, and other
addition to the important roles played        tools to draw attention to the issue, and serve as an objective and unbiased
by states, nonprofits, the private
                                              source of information about the selection of financial products and services. In
sector, and academia, federal
                                              prior work, GAO cited a 2009 report by the RAND Corporation in which 20
agencies promote financial literacy
through activities including print and
                                              federal agencies self-identified as having 56 federal financial literacy programs,
online materials, broadcast media,            but GAO’s subsequent analysis found substantial inconsistency in how different
individual counseling, and classroom          agencies defined and counted financial literacy programs. Based on a more
instruction.                                  consistent set of criteria, GAO identified 16 significant financial literacy programs
                                              or activities among 14 federal agencies, as well as 4 housing counseling
This testimony discusses (1) the              programs among 3 federally supported entities, in fiscal year 2010. The
federal government’s role in promoting        Comptroller General has initiated a multi-pronged strategy to address financial
financial literacy, including GAO’s role;     literacy issues. First, GAO will continue to evaluate federal efforts that directly
(2) the advantages and risks of               promote financial literacy. Second, it will encourage research of the various
financial literacy efforts being spread
                                              financial literacy initiatives to evaluate the relative effectiveness of different
across multiple federal agencies; and
                                              approaches. Third, GAO will look for opportunities to enhance financial literacy
(3) opportunities to enhance the
effectiveness of federal financial            as an integral component of certain regular federal interactions with the public.
literacy education efforts going              Finally, GAO has recently instituted a program to empower its own employees,
forward. This testimony is based on           which includes an internal website with information on personal financial matters
prior and ongoing work, for which GAO         and links to information on pay and benefits and referral services through its
reviewed agency budget documents,             counseling services office and a distinguished speaker series.
strategic plans, performance reports,         Having multiple federal agencies involved in financial literacy offers advantages
websites, and other materials;
                                              as well as risks. Some agencies have long-standing expertise and experience
convened forums of financial literacy
                                              addressing specific issue areas or populations, and providing information from
experts; and interviewed
representatives of federal agencies           multiple sources can increase consumer access and the likelihood of educating
and selected private and nonprofit            more people. However, the participation of multiple agencies also highlights the
organizations.                                risk of inefficiency and the need for strong coordination of their activities. GAO
                                              has found that the coordination and collaboration among federal agencies with
While this statement includes no new          regard to financial literacy has improved in recent years, in large part as a result
recommendations, in the past GAO              of the Financial Literacy and Education Commission. At the same time, GAO has
has made a number of                          found instances of overlap, in which multiple agencies or programs, including the
recommendations aimed at improving            new Bureau of Consumer Financial Protection, share similar goals and activities,
financial literacy efforts.
                                              underscoring the need for careful monitoring of the bureau’s efforts.
                                              In prior work GAO has noted the importance of program evaluation and the need
                                              to focus federal financial literacy efforts on initiatives that work. Federal agencies
                                              could potentially make the most of scarce resources by consolidating financial
                                              literacy efforts into the activities and agencies that are most effective. In addition,
                                              the Bureau of Consumer Financial Protection offers potential for enhancing the
                                              federal government’s role in financial literacy, but avoiding duplication will require
View GAO-12-636T. For more information,
contact Alicia Puente Cackley at (202) 512-   that it continue its efforts to delineate its financial literacy roles and
8678 or cackleya@gao.gov.                     responsibilities vis-à-vis those of other federal agencies with overlapping
                                              responsibilities.
                                                                                        United States Government Accountability Office
Chairman Akaka, Ranking Member Johnson, and Members of the
Subcommittee:

I am pleased to be here today to testify on the topic of financial literacy as
part of Financial Literacy Month 2012. Financial literacy plays an
important role in helping to promote the financial health and stability of
individuals and families. Economic changes in recent years have further
highlighted the need to empower all Americans to make informed
financial decisions. In his statement before you in April 2011, Comptroller
General Gene Dodaro emphasized his commitment to promoting greater
awareness of the importance of financial literacy in the United States. 1
Since that time, we have engaged in a series of reports and activities
aimed at focusing attention on the federal government’s financial literacy
efforts and providing insight into ways of improving the effectiveness of
those efforts. 2 For example, in October 2011 we held a forum on financial
literacy with participants that included representatives of federal, state,
and local government organizations; academic experts; nonprofit
practitioners; and representatives from the private sector. 3 The forum
focused on such topics as identifying the most effective approaches to
financial literacy and leveraging the unique role of the federal government
in promoting greater financial literacy.

In my statement today I will discuss (1) the federal government’s role in
promoting financial literacy, including the role of GAO; (2) the advantages
and risks of financial literacy efforts being spread across multiple federal
agencies; and (3) opportunities to enhance the effectiveness of federal
financial literacy education efforts going forward. This testimony is based
largely on selected prior work we have conducted on financial literacy. 4 In


1
 GAO, Financial Literacy: The Federal Government’s Role in Empowering Americans to
Make Sound Financial Choices, GAO-11-504T (Washington D.C.: Apr. 12, 2011).
2
 GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and
Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington
D.C.: Feb. 28, 2012); Highlights of a Forum: Financial Literacy: Strengthening
Partnerships in Challenging Times, GAO-12-299SP (Washington D.C.: Feb. 9, 2012); and
Financial Literacy: A Federal Certification Process for Providers Would Pose Challenges,
GAO-11-614 (Washington D.C.: June 28, 2011).
3
GAO-12-299SP.
4
 GAO-12-342SP, GAO-12-299SP, GAO-11-614, GAO-11-504T, and GAO, Highlights of a
GAO Forum: The Federal Government’s Role in Improving Financial Literacy,
GAO-05-93SP (Washington D.C.: Nov. 15, 2004).




Page 1                                                                      GAO-12-636T
             conducting that work, we collected information on the purpose,
             beneficiaries, and subject matter of federal financial literacy programs and
             activities through interviews with staff of federal agencies and through
             budget justifications, strategic plans, and other documents. We also
             reviewed the Financial Literacy and Education Commission’s 2011
             national strategy and implementation plan and memorandums of
             understanding and other documents related to collaboration among
             federal agencies. In addition, we convened forums of financial literacy
             experts and interviewed representatives of organizations that address
             financial literacy within the federal, state, private, nonprofit, and academic
             sectors.

             The work on which this statement was based was largely performed from
             May 2011 to February 2012 in accordance with generally accepted
             government auditing standards. Those standards require that we plan
             and perform the audit to obtain sufficient, appropriate evidence to provide
             a reasonable basis for our findings and conclusions based on our audit
             objectives. We believe that the evidence obtained provides a reasonable
             basis for our findings and conclusions based on our audit objectives.


             There is no single definition for financial literacy, which is sometimes also
Background   referred to as financial capability, but it has previously been described as
             the ability to make informed judgments and to take effective actions
             regarding current and future use and management of money. Financial
             literacy encompasses financial education—the processes whereby
             individuals improve their knowledge and understanding of financial
             products, services, and concepts. However, being financially literate
             refers to more than simply being knowledgeable about financial matters; it
             also entails utilizing that knowledge to make informed decisions, avoid
             pitfalls, and take other actions to improve one’s present and long-term
             financial well-being. Federal, state, and local government agencies,
             nonprofits, the private sector, and academia all play important roles in
             providing financial education resources, which can include print and
             online materials, broadcast media, individual counseling, and classroom
             instruction.

             Evidence indicates that many U.S. consumers could benefit from
             improved financial literacy efforts. In a 2010 survey of U.S. consumers
             prepared for the National Foundation for Credit Counseling, a majority of




             Page 2                                                             GAO-12-636T
                       consumers reported they did not have a budget and about one-third were
                       not saving for retirement. 5 In a 2009 survey of U.S. consumers by the
                       FINRA Investor Education Foundation, a majority believed themselves to
                       be good at dealing with day-to-day financial matters, but the survey also
                       revealed that many had difficulty with basic financial concepts. 6 Further,
                       about 25 percent of U.S. households either have no checking or savings
                       account or rely on alternative financial products or services that are likely
                       to have less favorable terms or conditions, such as nonbank money
                       orders, nonbank check-cashing services, or payday loans. 7 As a result,
                       many Americans may not be managing their finances in the most
                       effective manner for maintaining or improving their financial well-being. In
                       addition, individuals today have more responsibility for their own
                       retirement savings because traditional defined-benefit pension plans have
                       increasingly been replaced by defined-contribution pension plans over the
                       past two decades. 8 As a result, financial skills are increasingly important
                       for those individuals in or planning for retirement to help ensure that
                       retirees can enjoy a comfortable standard of living.


                       Efforts to improve financial literacy in the United States involve a range of
The Federal            public, nonprofit, and private participants. Among those participants, the
Government Plays a     federal government is distinctive for its size and reach, and for the
                       diversity of its components, which address a wide array of issues and
Wide-Ranging Role in   populations. At our forum last year on financial literacy, many participants
Promoting Financial    said that the federal government had a unique role to play in promoting
                       greater financial capability. 9 They noted that the federal government has
Literacy               a built-in “bully pulpit” that can be used to draw attention to this issue.
                       Participants also highlighted the federal government’s ability to convene
                       the numerous agencies and entities involved in financial literacy, noting


                       5
                        Harris Interactive Inc., prepared for The National Foundation for Credit Counseling, The
                       2010 Consumer Financial Literacy Survey Final Report (April 2010).
                       6
                        FINRA Investor Education Foundation, Financial Capability in the United States, Initial
                       Report of Research Findings from the 2009 National Survey, A Component of the National
                       Financial Capability Study (New York, N.Y.: Dec. 1, 2009).
                       7
                        Federal Deposit Insurance Corporation (FDIC), FDIC National Survey of Unbanked and
                       Underbanked Households (Washington, D.C.: December 2009).
                       8
                        GAO, Defined Benefit Pensions: Survey Results of the Nation’s Largest Private Defined
                       Benefit Plan Sponsors, GAO-09-291 (Washington, D.C.: Mar. 30, 2009).
                       9
                       GAO-12-299SP.




                       Page 3                                                                        GAO-12-636T
that the government has a powerful ability to bring people together. In
addition, some participants noted the federal government’s ability to take
advantage of existing distribution channels and points of contact between
the government and citizens to distribute messages about financial
literacy. In our ongoing work, we have found examples of federal
agencies acting on such opportunities—for example, the Securities and
Exchange Commission has worked with the Internal Revenue Service to
include an insert about its investor education resources, including its
“Investor.gov” education website, in the mailing of tax refund checks.

At our first forum on financial literacy in 2004, participants noted that the
federal government can serve as an objective and unbiased source of
information, particularly in terms of helping consumers make wise
decisions about the selection of financial products and services. 10 Some
participants expressed the belief that while the private sector offers a
number of good financial literacy initiatives, it is ultimately motivated by its
own financial interests, while the federal government may be in a better
position to offer broad-based, noncommercial financial education.

In preliminary results from an ongoing review, we have identified that, in
fiscal year 2010, there were 16 significant financial literacy programs or
activities among 14 federal agencies, as well as 4 housing counseling
programs among 2 federal agencies and a federally chartered nonprofit
corporation. We defined “significant” financial literacy programs or
activities as those that were relatively comprehensive in scope or scale
and included financial literacy as a key objective rather than a tangential
goal. 11 In prior work, we cited a 2009 report that had identified 56 federal


10
  GAO-05-93SP.
11
  According to our criteria, significant financial literacy and education activities were those
for which primary goals were to educate, inform, or encourage individuals to make
informed judgments and take effective actions regarding the current and future use and
management of money. However, we excluded (1) those for which financial literacy was
only a minimal component; (2) programs that provided financial information related to the
administration of the program itself (e.g., information on applying for student financial aid
or evaluating Medicare choices) rather than information aimed at increasing the
beneficiaries’ financial literacy and comprehension more generally; (3) activities or
programs that were purely internal to the agency, such as information provided to agency
employees on their employment and retirement benefits; and 4) activities that represented
individualized services or advice (e.g., assistance with tax preparation or development of a
debt management plan). We included as federal programs those of NeighborWorks®
America, a government-chartered, nonprofit corporation that receives federal funding for
housing counseling, including through an annual appropriation from Congress.




Page 4                                                                           GAO-12-636T
financial literacy programs among 20 agencies. That report, conducted by
the RAND Corporation, was based on a survey that had asked federal
agencies to self-identify their financial literacy efforts. 12 However, our
subsequent analysis of these 56 programs found that there was a high
degree of inconsistency in how different agencies defined financial
literacy programs or efforts and whether they counted related efforts as
one or multiple programs. We believe that our count of 16 significant
federal financial literacy programs or activities and 4 housing counseling
programs is based on a more consistent set of criteria. 13

During his confirmation hearing, Comptroller General Dodaro noted that
financial literacy was an area of priority for him, and he has initiated a
multi-pronged strategy for GAO to address financial literacy issues. First,
we will continue to evaluate federal efforts that directly promote financial
literacy. In addition to our recent financial literacy forum, we have ongoing
work that focuses on, among other things, the cost of federal financial
literacy activities, the federal government’s coordination of these
activities, and what is known about their effectiveness. Second, we will
encourage research of the various financial literacy initiatives to evaluate
the relative effectiveness of different financial literacy approaches. Third,
we will look for opportunities to enhance financial literacy as an integral
component of certain regular federal interactions with the public. Finally,
we have recently instituted a program to empower GAO’s own
employees. This program includes a distinguished speaker series, as well
as an internal website with information on personal financial matters and
links to information on pay and benefits and referral services through
GAO’s counseling services office.




12
  GAO, List of Selected Federal Programs That Have Similar or Overlapping Objectives,
Provide Similar Services, or Are Fragmented Across Government Missions,
GAO-11-474R (Washington, D.C.: Mar. 18, 2011); and Opportunities to Reduce Potential
Duplication in Government Programs, Save Tax Dollars, and Enhance Revenue,
GAO-11-318SP (Washington, D.C.: Mar. 1, 2011). Angela A. Hung, Kata Mihaly, and
Joanne K. Yoong (RAND Corporation), Federal Financial and Economic Literacy
Education Programs, 2009 (Santa Monica, Calif.: 2010), accessed April 19, 2012,
http://rand.org/pubs/technical_reports/2010/RAND_TR857.pdf.
13
  Our review was based on programs in place in fiscal year 2010; at least three of the
programs in place at that time were not funded in fiscal year 2012.




Page 5                                                                        GAO-12-636T
                        Having multiple federal agencies involved in financial literacy efforts can
Having Multiple         have certain advantages. In particular, providing information from multiple
Federal Agencies        sources can increase consumer access and the likelihood of educating
                        more people. Moreover, certain agencies may have deep and long-
Involved in Financial   standing expertise and experience addressing specific issue areas or
Literacy Offers         serving specific populations. For example, the Securities and Exchange
Advantages as Well as   Commission has efforts in place to protect securities investors from
                        fraudulent schemes, while the Department of Housing and Urban
Risks                   Development (HUD) oversees most, but not all, federally supported
                        housing counseling. Similarly, the Department of Defense (DOD) may be
                        the agency most able to efficiently and effectively deliver financial literacy
                        programs and products to servicemembers and their families. However,
                        as we stated in a June 2011 report, relatively few evidence-based
                        evaluations of financial literacy programs have been conducted, limiting
                        what is known about which specific methods and strategies—and which
                        federal financial literacy activities—are most effective. 14

                        Further, the participation of multiple agencies highlights the need for
                        strong coordination of their activities. In general, we have found that the
                        coordination and collaboration among federal agencies with regard to
                        financial literacy have improved in recent years, in large part due to the
                        multiagency Financial Literacy and Education Commission. The
                        commission was created by Congress in 2003 and charged, among other
                        things, with developing a national strategy to promote financial literacy
                        and education, coordinating federal efforts, and identifying areas of
                        overlap and duplication. Among other things, the commission, in concert
                        with the Department of the Treasury, which provides its primary staff
                        support, has served as a central clearinghouse for federal financial
                        literacy resources—for example, it created a centralized federal website
                        and has an ongoing effort to develop a catalog of federal research on
                        financial literacy. The commission’s 2011 national strategy identified five
                        action areas, one of which was to further emphasize the role of the
                        commission in coordination. The strategy’s accompanying
                        Implementation Plan lays out plans to coordinate communication among
                        federal agencies, improve strategic partnerships, and develop channels of
                        communication with other entities, including the President’s Advisory
                        Council on Financial Capability and the National Financial Education
                        Network of State and Local Governments. The Financial Literacy and



                        14
                         GAO-11-614.




                        Page 6                                                             GAO-12-636T
Education Commission’s success in implementing these elements of the
national strategy is key, given the inherently challenging task of
coordinating the work of the commission’s many member agencies—each
of which has its own set of interests, resources, and constituencies.
Further, the addition of the Bureau of Consumer Financial Protection,
whose director serves as the Vice Chair of the commission, adds a new
player to the mix.

In our recent and ongoing work, we have found instances in which
multiple agencies or programs share similar goals and activities, which
raises questions about the efficiency of some federal financial literacy
efforts. For example, four federal agencies and one government-
chartered nonprofit corporation provide or support various forms of
housing counseling to consumers—DOD, HUD, the Department of
Veterans Affairs, the Department of the Treasury, and NeighborWorks
America. Other examples of overlap lie in the financial literacy
responsibilities of the Bureau of Consumer Financial Protection, which
was created by the Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act). The act established within the bureau an
Office of Financial Education and charged this office with developing and
implementing a strategy to improve financial literacy through activities
including opportunities for consumers to access, among other things,
financial counseling; information to assist consumers with understanding
credit products, histories, and scores; information about saving and
borrowing tools; and assistance in developing long-term savings
strategies. This office presents an opportunity to further promote
awareness, coordinate efforts, and fill gaps related to financial literacy. At
the same time, the duties this office is charged with fulfilling are in some
ways similar to those of a separate Office of Financial Education and
Financial Access within the Department of the Treasury, a small office
that also seeks to broadly improve Americans’ financial literacy. In
addition, the Dodd-Frank Act charges the Bureau of Consumer Financial
Protection with developing and implementing a strategy on improving the
financial literacy of consumers, even though the multiagency Financial
Literacy and Education Commission already has its own statutory
mandate to develop, and update as necessary, a national strategy for
financial literacy. As the bureau has been staffing up and planning its
financial education activities, it has been in regular communication with
the Department of the Treasury and with other members of the Financial
Literacy and Education Commission, and agency staff say they are
seeking to coordinate their respective roles and activities.




Page 7                                                             GAO-12-636T
                       The Dodd-Frank Act also creates within the bureau an Office of Financial
                       Protection for Older Americans, which is charged with helping seniors
                       recognize warning signs of unfair, deceptive, or abusive practices and
                       protect themselves from such practices; providing one-on-one financial
                       counseling on issues including long-term savings and later-life economic
                       security; and monitoring the legitimacy of certifications of financial
                       advisers who advise seniors. These activities may overlap with those of
                       the Federal Trade Commission, which also plays a role in helping seniors
                       avoid unfair and deceptive practices. Further, the Department of Labor
                       and the Social Security Administration both have initiatives in place to
                       help consumers plan for retirement, and the Securities and Exchange
                       Commission has addressed concerns about the designations and
                       certifications used by financial advisers, who often play a role in
                       retirement planning. 15 Officials at the Bureau of Consumer Financial
                       Protection told us that they have been coordinating their financial literacy
                       roles and activities with those of other federal agencies to avoid
                       duplication of effort.


                       In prior work we have noted the importance of program evaluation and
Program Evaluation     the need to focus federal financial literacy efforts on initiatives that work.
and the Bureau of      Relatively few evidence-based evaluations of financial literacy programs
                       have been conducted, limiting what is known about which specific
Consumer Financial     methods and strategies are most effective. Financial literacy program
Protection May Offer   evaluations are most reliable and definitive when they track participants
Avenues to Enhance     over time, include a control group, and measure the program’s impact on
                       consumers’ behavior. However, such evaluations are typically expensive,
Effectiveness          time-consuming, and methodologically challenging. Based on our
                       previous work, it appears that no single approach, delivery mechanism, or
                       technology constitutes best practice, but there is some consensus on key


                       15
                         The Federal Trade Commission’s Division of Consumer and Business Education plans,
                       develops, and implements various web-based financial literacy activities that focus on
                       consumer protection, some of which have focused on scams targeted at seniors. The
                       Department of Labor’s Retirement Savings Education Campaign seeks to increase
                       retirement savings through workplace plans so that employees are better prepared for a
                       secure retirement. The Social Security Administration’s (SSA) Special Initiative to
                       Encourage Savings focuses on saving and retirement issues and informing the public
                       about SSA’s programs related to old-age, survivors, and disability insurance system. The
                       Securities and Exchange Commission’s efforts to address concerns about the
                       designations and certifications used by financial advisers have included conducting focus
                       groups with investors on the topic and improving the disclosures that financial advisers
                       must provide to clients.




                       Page 8                                                                       GAO-12-636T
common elements for successful financial education programs, such as
timely and relevant content, accessibility, cultural sensitivity, and an
evaluation component.

There are several efforts under way that seek to enhance evaluation of
federal financial literacy programs. For example, the Financial Literacy
and Education Commission has begun to establish a clearinghouse of
evidence-based research and evaluation studies, current financial topics
and trends of interest to consumers, innovative approaches, and best
practices. In addition, the Bureau of Consumer Protection recently
contracted with the Urban Institute for a financial education program
evaluation project, which will assess the effectiveness of two existing
financial education programs and seeks to identify program elements that
improve consumers’ confidence about financial matters. We believe these
measures are positive steps because federal agencies could potentially
make the most of scarce resources by consolidating financial literacy
efforts into the activities and agencies that are most effective.

The Bureau of Consumer Financial Protection was charged by statute
with a key role in improving Americans’ financial literacy and is being
provided with resources to do so. As such, the bureau offers potential in
enhancing the federal government’s role in financial literacy. At the same
time, as we have seen, some of its responsibilities overlap with those of
other agencies, which highlights the need for coordination and may offer
opportunities for consolidation. As the bureau’s financial literacy activities
evolve and are implemented, it will be important to evaluate how those
efforts are working and make appropriate adjustments that might promote
greater efficiency and effectiveness. In addition, the overlap we have
identified among programs and activities increases the risk of inefficiency
and emphasizes the importance of coordination among financial
participants. This underscores the importance of steps the Bureau of
Consumer Financial Protection has been taking to delineate its roles and
responsibilities related to financial literacy vis-à-vis those of other federal
agencies, which we believe is critical in order to minimize overlap and the
potential for duplication.


Chairman Akaka, Ranking Member Johnson, this completes my prepared
statement. I would be happy to respond to any questions you or other
Members of the Subcommittee may have at this time.

For future contacts about this testimony, please contact Alicia Puente
Cackley at (202) 512-8678 or at cackleya@gao.gov. Contact points for


Page 9                                                              GAO-12-636T
           our Offices of Congressional Relations and Public Affairs may be found
           on the last page of this statement. Jason Bromberg, Mary Coyle, Roberto
           Piñero, Rhonda Rose, Jennifer Schwartz, and Andrew Stavisky also
           made key contributions to this statement.




(250672)
           Page 10                                                      GAO-12-636T
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