| background |
NOTICE: None of these questions and answers constitute legal
advice. To obtain legal advice, consult with an attorney. This is
especially important in divorce and family law matters, in which
outcomes are often peculiar to the particular facts and
circumstances of the case.
Q. What types of retirement accounts are at issue in divorce?
A. Any pension, retirement, profit sharing, or deferred
compensation plan or account is at issue. Retirement assets include
IRA, 401K, 403B, TSP, profit sharing, money purchase, pension,
stock option, annuity, and any other deferred compensation
accounts or plans; military, FERS, CSRS, State, county, municipal,
union, and private defined benefit plans and defined contribution
plans; and survivor benefits.
Q. In a Maryland divorce, what retirement assets are marital
property?
A. Any pension, retirement, profit sharing, or deferred
compensation plan or account acquired during marriage is marital
property. So, for example, the right to receive retirement benefits
under a private or public employee pension plan, whether or not
vested, matured, or contributory, is property which, if acquired
during marriage, constitutes marital property.
Q. In a Maryland divorce, what retirement assets are
nonmarital property?
A. Any pension, retirement, profit sharing, or deferred
compensation plan or account acquired before marriage, by
inheritance or gift from a third party, excluded by valid agreement,
or traceable to any of these sources is nonmarital property. So, for
example, payments made toward a 401K prior to marriage are
nonmarital property. So, too, the increase in 401K's value during
marriage which is "directly traceable" to the portion acquired prior to
marriage is nonmarital property.
Q. What if only one spouse contributed to retirement benefits
acquired during marriage?
A. When the right to receive retirement benefits is acquired during
marriage, it is marital property subject to equitable distribution,
even when only one spouse contributed economically to earn that
right.
Q. Are employer matching contributions to an employee
retirement asset treated differently than employee
contributions?
A. No.
Q. In a Maryland divorce proceeding, is transfer or
distribution of retirement assets required?
A. No. The Maryland statute governing disposition of marital
property gives the court discretion to transfer interests in
retirement, pension, and deferred compensation plans in divorce
proceedings, but does not require the court to do so.
The court has much discretion in determining the best way to
allocate marital assets between parties. Whether to award
retirement funds is but one of its options. If the court decides to
award part of a retirement plan or similar account, it has
considerable flexibility in determining how and when payments will be
received. However, flexibility and discretion do not equate to a
mandate that every divorce litigant with a retirement account must
share it with an ex-spouse.
The retirement account or pension plan is often, next to the family
home, a divorcing party's largest asset, so it may become necessary
for the court to consider dividing it. However, for example, where
the retirement account represents only a fraction of the total marital
property, some of the retirement asset was acquired before
marriage, and other funds are available for a monetary award, the
court may decide to let the retirement asset remain untouched.
Q. What methods are used to determine the value of
retirement benefits?
A. For purposes of divorce in Maryland, a court has broad discretion
in evaluating pensions and retirement benefits. In a Maryland divorce
action, pension or retirement benefits can be valued (1) as equal to
an employee's contributions to the pension plus accrued interest or
market experience thereon, (2) as the "present value" of future
benefits expected to be received by the employee after retirement,
or (3) through determination of a percentage to be paid to the
nonemployee spouse from any future retirement payments received
by an employee spouse, payable "as, if, and when" received. The
method used for valuing a spouse's pension or retirement benefits
in dividing marital property upon divorce will depend upon the facts
and circumstances of the particular case.
Q. What is the "present value" method?
A. Under this approach, benefits payable in the future have to be
discounted for interest earned in the future, for mortality, and for
vesting (if not fully vested at the time of divorce). The benefits then
have to be calculated with respect to the employee-spouse's life
expectancy as a retiree. This calculation involves considerable
uncertainty, and the amount yielded changes as different
assumptions are used with respect to mortality, job turn-over, and
other factors. It has been recognized that this kind of calculation
can be very difficult and that, where it becomes too speculative, the
trial court should use a different method of valuation.
Q. When are payments made to the non-employee spouse
under the "contributions plus" method or the "present value"
method?
A. Under either the "contributions plus" method or the "present
value" method, the court has discretion to order payment to the
non-employee spouse in either a lump sum or in installments,
depending primarily on other assets and relative financial positions
of the parties.
Q. Are there circumstances when the court does not
determine the value of retirement assets?
A. The court need not determine the value of a pension, retirement,
profit sharing, or deferred compensation plan, unless a party in a
divorce proceeding has given notice that the party objects to a
distribution of retirement benefits on an "if, as, and when" basis. If
timely notice is not given, any objection to a distribution on an "if,
as, and when" basis shall be deemed to be waived unless good
cause is shown.
Q. What is an "if, as, and when" award, and how does it
work?
A. The third method, which has been referred to as the "if, as and
when" method, recognizes that the value of a pension at the time of
divorce cannot be ascertained with certainty until the employee
spouse retires.
This third method, which has been used widely, uses a formula for
computing the nonemployee spouse's share of any future payments
the employee spouse receives under the plan, payable to the
non-employee spouse as, if, and when paid to the
employee-spouse. Under this approach, of course, it is
unnecessary to determine the value of the pension at all. The court
need do no more than state the formula to be used to determine
the percentage to which the non-employee spouse will be entitled.
Q. What formula is used in an "if, as, and when" award?
A. The formula used in an "if, as, and when" award of pension
benefits, referred to as the Bangs formula, calculates the value of
the pension to which the non-employee spouse is entitled as a
percentage, usually 50%, multiplied by a fraction, the numerator of
which is the number of months and years of employment during the
marriage, and the denominator of which is the total number of
months and years of employment at the time of retirement.
Q. Why isn't the non-employee spouse's share frozen at the
time of divorce?
A. Maryland's appellate courts have disapproved of attempts to
freeze the non-employee spouse's share of the employee spouse's
pension to its then current fixed value at the time of divorce. They
have observed that an employee spouse's increases in salary after
divorce would be based in part on work performance during the
marriage. Moreover, any future adjustments by management might
well relate to the length of the employee spouse's total service,
including the period of the marriage.
Q. Does it matter whether alimony is awarded to either party?
A. The court may transfer ownership of an interest in a pension,
retirement, profit sharing, or deferred compensation plan, from one
party to either or both parties as an adjustment of the equities and
rights of the parties concerning marital property, whether or not
alimony is awarded.
Q. Can an "as, if, and when" award be made even if one party
wants a lump sum?
A. Yes. Awarding a nonemployee spouse a portion of an employee
spouse's pension benefits on an "as, if, and when" basis, rather
than as a lump sum, is permissible, despite the employee spouse's
preference for a lump sum award. Likewise, awarding a
nonemployee spouse a portion of an employee spouse's pension
benefits on an "as, if, and when" basis, rather than as a lump sum,
is permissible, despite the nonemployee spouse's preference for a
lump sum award.
Q. How are survivor benefits treated?
A. Survivor benefits attached to a pension are property separate
and apart from the pension itself. Although survivor benefits are
like a pension, they have been treated as marital or nonmarital
property in their own right, depending on when and how the
survivor benefits were acquired.
A spouse seeking to recover an interest in the survivor benefit
attached to the other spouse's pension must request the survivor
benefit in addition to any request for the pension benefit itself.
Q. Can a divorced party reduce a former spouse's share of
retirement benefits by electing survivor benefits for someone
else?
A. A divorced party with a retirement cannot reduce a former
spouse's share of pension benefits by electing survivor benefits for
someone other than the ex-spouse. Although an employee spouse
is free to elect survivor benefits for someone other than the
nonemployee former spouse, the nonemployee spouse's pension
benefits should not be less than they would have been if such an
election had not been made.
Q. If a transfer or distribution of retirement assets takes place
in connection with a divorce proceeding, are income taxes
due?
A. Done properly, transfers between spouses incident to a divorce
or separation instrument are not taxable events for either the
transferor or the transferee. Consult a tax advisor with experience
in transfers incident to divorce for guidance on how to transfer
retirement assets properly.
Of course, previously tax-deferred income will be taxable to the
transferee spouse upon withdrawal from a retirement account.
However, under certain circumstances, the transferee spouse may
avoid withdrawal penalties. Consult a tax advisor for guidance on
how to do so.
Q. What is a Qualified Domestic Relations Order or QDRO?
A. A Qualified Domestic Relations Order, or QDRO (pronounced
"quadro"), is one type of order that is issued by a court to transfer
retirement assets. Although the term has a technical meaning,
referring to employer-sponsored plans subject to ERISA, it has
come to be used to refer to just about any order to transfer
retirement assets. A QDRO must be approved by the administrator
of the retirement plan as well as the court before it will be carried
out.
Q. When is a QDRO needed to transfer or distribute
retirement benefits?
A. Pension plan benefits payable to an employee spouse under an
ERISA plan can be redirected to an alternate payee non-employee
spouse only through the mechanism of a Qualified Domestic
Relations Order or QDRO. Absent such a qualified order, not only
will the pension plan administrator refuse to implement the court's
decision, but there is at least a reasonable argument that a
non-qualified order may be invalid even as between the parties.
Q. What will prevent a retirement order from being
"qualified"?
A. An order will not be "qualified" if it grants any type or form of
benefit, or any option, not otherwise provided under the plan, or
results in a plan having to pay increased benefits.
Q. In a QDRO, what do the terms "participant" and "alternate
payee" mean?
A. These are terms used in QDROs and other retirement orders.
"Participant" refers to the spouse who is an employee or former
employee of the plan sponsor, and "alternate payee" refers to a
nonemployee spouse.
Under ERISA, an alternate payee is "any spouse, former spouse,
child, or other dependent of a participant who is recognized by a
domestic relations order as having a right to receive all, or a portion
of, the benefits payable under the plan with respect to such
participant." An alternate payee, under a QDRO, is treated as a plan
beneficiary.
Q. How do pension or retirement assets get divided by a
QDRO in a divorce?
A. QDROs can and must be drafted to provide for differing payment
types depending upon the type of plan involved. One type of
payment is a "shared payment." A second type of payment is a
"separate interest."
Q. What is a "shared payment" and how does it work?
A. One type of payment available is a "shared payment," whereby
the QDRO seeks to divide only actual payments made with respect
to the participant under the plan. Under a shared payment
approach, only the participant's stream of income is divided and the
alternate payee is not actually given a portion of the actual
retirement benefit. Therefore, the alternate payee's right to receive
payment is dependent upon the participant's receipt of payments
under the plan and he or she will not receive a distribution unless,
and until, the participant is in pay status. Accordingly, QDROs
providing for shared payments are typically entered in cases where
the participant is already receiving payments under the plan.
Q. What is a "separate interest" payment and how does it
work?
A. Under a "separate interest" QDRO, the participant's actual
retirement benefit is divided, and the alternate payee is permitted to
receive a portion of the retirement benefit to be paid at a time and
in a form different from that chosen by the participant. A separate
interest QDRO is often preferred where the order seeks to divide a
pension as part of the marital property as opposed to providing for
support payments. A separate interest award is permitted by
Maryland law whether the participant spouse's interest in the plan is
vested or unvested at the time of divorce.
Q. What happens when one spouse puts nonmarital funds
into an IRA of the other spouse?
A. One spouse's creation of an individual retirement account or IRA
solely in the other spouse's name but primarily with the contributor
spouse's nonmarital funds may indicate the contributor spouse's
intent to make a gift to the recipient spouse, and to relinquish
equitable interest in the funds. The contributor spouse's conduct
may support classification of the IRA as the recipient spouse's
nonmarital property upon divorce.
Q. After divorce, can one spouse collect Social Security
benefits based on the other's record?
A. If a divorce occurs after at least 10 years of marriage, you can
collect retirement benefits based on your former spouse's Social
Security earnings record if you are at least age 62 and if your
former spouse is entitled to or receiving benefits. If you remarry,
you generally cannot collect benefits on your former spouse's
earnings record unless your later marriage ends (whether by death,
divorce, or annulment). Get more information at
www.socialsecurity.gov.
Q. How does divorce and remarriage affect Social Security
survivor's benefits?
A. If your divorced spouse dies, you can receive benefits as a
widow/widower if the marriage lasted 10 years or more. Benefits
paid to a surviving divorced spouse who is 60 or older will not affect
the benefit rates for other survivors receiving benefits.
In general, you cannot receive survivors benefits if you remarry
before the age of 60 unless the later marriage ends, whether by
death, divorce, or annulment.
If you remarry after age 60 (50 if disabled), you can still collect
benefits on your former spouse's record. When you reach age 62 or
older, you may get retirement benefit on the record of your new
spouse if they are higher. Your remarriage would have no effect on
the benefits being paid to your children.
Get more information at www.socialsecurity.gov.
advice. To obtain legal advice, consult with an attorney. This is
especially important in divorce and family law matters, in which
outcomes are often peculiar to the particular facts and
circumstances of the case.
Q. What types of retirement accounts are at issue in divorce?
A. Any pension, retirement, profit sharing, or deferred
compensation plan or account is at issue. Retirement assets include
IRA, 401K, 403B, TSP, profit sharing, money purchase, pension,
stock option, annuity, and any other deferred compensation
accounts or plans; military, FERS, CSRS, State, county, municipal,
union, and private defined benefit plans and defined contribution
plans; and survivor benefits.
Q. In a Maryland divorce, what retirement assets are marital
property?
A. Any pension, retirement, profit sharing, or deferred
compensation plan or account acquired during marriage is marital
property. So, for example, the right to receive retirement benefits
under a private or public employee pension plan, whether or not
vested, matured, or contributory, is property which, if acquired
during marriage, constitutes marital property.
Q. In a Maryland divorce, what retirement assets are
nonmarital property?
A. Any pension, retirement, profit sharing, or deferred
compensation plan or account acquired before marriage, by
inheritance or gift from a third party, excluded by valid agreement,
or traceable to any of these sources is nonmarital property. So, for
example, payments made toward a 401K prior to marriage are
nonmarital property. So, too, the increase in 401K's value during
marriage which is "directly traceable" to the portion acquired prior to
marriage is nonmarital property.
Q. What if only one spouse contributed to retirement benefits
acquired during marriage?
A. When the right to receive retirement benefits is acquired during
marriage, it is marital property subject to equitable distribution,
even when only one spouse contributed economically to earn that
right.
Q. Are employer matching contributions to an employee
retirement asset treated differently than employee
contributions?
A. No.
Q. In a Maryland divorce proceeding, is transfer or
distribution of retirement assets required?
A. No. The Maryland statute governing disposition of marital
property gives the court discretion to transfer interests in
retirement, pension, and deferred compensation plans in divorce
proceedings, but does not require the court to do so.
The court has much discretion in determining the best way to
allocate marital assets between parties. Whether to award
retirement funds is but one of its options. If the court decides to
award part of a retirement plan or similar account, it has
considerable flexibility in determining how and when payments will be
received. However, flexibility and discretion do not equate to a
mandate that every divorce litigant with a retirement account must
share it with an ex-spouse.
The retirement account or pension plan is often, next to the family
home, a divorcing party's largest asset, so it may become necessary
for the court to consider dividing it. However, for example, where
the retirement account represents only a fraction of the total marital
property, some of the retirement asset was acquired before
marriage, and other funds are available for a monetary award, the
court may decide to let the retirement asset remain untouched.
Q. What methods are used to determine the value of
retirement benefits?
A. For purposes of divorce in Maryland, a court has broad discretion
in evaluating pensions and retirement benefits. In a Maryland divorce
action, pension or retirement benefits can be valued (1) as equal to
an employee's contributions to the pension plus accrued interest or
market experience thereon, (2) as the "present value" of future
benefits expected to be received by the employee after retirement,
or (3) through determination of a percentage to be paid to the
nonemployee spouse from any future retirement payments received
by an employee spouse, payable "as, if, and when" received. The
method used for valuing a spouse's pension or retirement benefits
in dividing marital property upon divorce will depend upon the facts
and circumstances of the particular case.
Q. What is the "present value" method?
A. Under this approach, benefits payable in the future have to be
discounted for interest earned in the future, for mortality, and for
vesting (if not fully vested at the time of divorce). The benefits then
have to be calculated with respect to the employee-spouse's life
expectancy as a retiree. This calculation involves considerable
uncertainty, and the amount yielded changes as different
assumptions are used with respect to mortality, job turn-over, and
other factors. It has been recognized that this kind of calculation
can be very difficult and that, where it becomes too speculative, the
trial court should use a different method of valuation.
Q. When are payments made to the non-employee spouse
under the "contributions plus" method or the "present value"
method?
A. Under either the "contributions plus" method or the "present
value" method, the court has discretion to order payment to the
non-employee spouse in either a lump sum or in installments,
depending primarily on other assets and relative financial positions
of the parties.
Q. Are there circumstances when the court does not
determine the value of retirement assets?
A. The court need not determine the value of a pension, retirement,
profit sharing, or deferred compensation plan, unless a party in a
divorce proceeding has given notice that the party objects to a
distribution of retirement benefits on an "if, as, and when" basis. If
timely notice is not given, any objection to a distribution on an "if,
as, and when" basis shall be deemed to be waived unless good
cause is shown.
Q. What is an "if, as, and when" award, and how does it
work?
A. The third method, which has been referred to as the "if, as and
when" method, recognizes that the value of a pension at the time of
divorce cannot be ascertained with certainty until the employee
spouse retires.
This third method, which has been used widely, uses a formula for
computing the nonemployee spouse's share of any future payments
the employee spouse receives under the plan, payable to the
non-employee spouse as, if, and when paid to the
employee-spouse. Under this approach, of course, it is
unnecessary to determine the value of the pension at all. The court
need do no more than state the formula to be used to determine
the percentage to which the non-employee spouse will be entitled.
Q. What formula is used in an "if, as, and when" award?
A. The formula used in an "if, as, and when" award of pension
benefits, referred to as the Bangs formula, calculates the value of
the pension to which the non-employee spouse is entitled as a
percentage, usually 50%, multiplied by a fraction, the numerator of
which is the number of months and years of employment during the
marriage, and the denominator of which is the total number of
months and years of employment at the time of retirement.
Q. Why isn't the non-employee spouse's share frozen at the
time of divorce?
A. Maryland's appellate courts have disapproved of attempts to
freeze the non-employee spouse's share of the employee spouse's
pension to its then current fixed value at the time of divorce. They
have observed that an employee spouse's increases in salary after
divorce would be based in part on work performance during the
marriage. Moreover, any future adjustments by management might
well relate to the length of the employee spouse's total service,
including the period of the marriage.
Q. Does it matter whether alimony is awarded to either party?
A. The court may transfer ownership of an interest in a pension,
retirement, profit sharing, or deferred compensation plan, from one
party to either or both parties as an adjustment of the equities and
rights of the parties concerning marital property, whether or not
alimony is awarded.
Q. Can an "as, if, and when" award be made even if one party
wants a lump sum?
A. Yes. Awarding a nonemployee spouse a portion of an employee
spouse's pension benefits on an "as, if, and when" basis, rather
than as a lump sum, is permissible, despite the employee spouse's
preference for a lump sum award. Likewise, awarding a
nonemployee spouse a portion of an employee spouse's pension
benefits on an "as, if, and when" basis, rather than as a lump sum,
is permissible, despite the nonemployee spouse's preference for a
lump sum award.
Q. How are survivor benefits treated?
A. Survivor benefits attached to a pension are property separate
and apart from the pension itself. Although survivor benefits are
like a pension, they have been treated as marital or nonmarital
property in their own right, depending on when and how the
survivor benefits were acquired.
A spouse seeking to recover an interest in the survivor benefit
attached to the other spouse's pension must request the survivor
benefit in addition to any request for the pension benefit itself.
Q. Can a divorced party reduce a former spouse's share of
retirement benefits by electing survivor benefits for someone
else?
A. A divorced party with a retirement cannot reduce a former
spouse's share of pension benefits by electing survivor benefits for
someone other than the ex-spouse. Although an employee spouse
is free to elect survivor benefits for someone other than the
nonemployee former spouse, the nonemployee spouse's pension
benefits should not be less than they would have been if such an
election had not been made.
Q. If a transfer or distribution of retirement assets takes place
in connection with a divorce proceeding, are income taxes
due?
A. Done properly, transfers between spouses incident to a divorce
or separation instrument are not taxable events for either the
transferor or the transferee. Consult a tax advisor with experience
in transfers incident to divorce for guidance on how to transfer
retirement assets properly.
Of course, previously tax-deferred income will be taxable to the
transferee spouse upon withdrawal from a retirement account.
However, under certain circumstances, the transferee spouse may
avoid withdrawal penalties. Consult a tax advisor for guidance on
how to do so.
Q. What is a Qualified Domestic Relations Order or QDRO?
A. A Qualified Domestic Relations Order, or QDRO (pronounced
"quadro"), is one type of order that is issued by a court to transfer
retirement assets. Although the term has a technical meaning,
referring to employer-sponsored plans subject to ERISA, it has
come to be used to refer to just about any order to transfer
retirement assets. A QDRO must be approved by the administrator
of the retirement plan as well as the court before it will be carried
out.
Q. When is a QDRO needed to transfer or distribute
retirement benefits?
A. Pension plan benefits payable to an employee spouse under an
ERISA plan can be redirected to an alternate payee non-employee
spouse only through the mechanism of a Qualified Domestic
Relations Order or QDRO. Absent such a qualified order, not only
will the pension plan administrator refuse to implement the court's
decision, but there is at least a reasonable argument that a
non-qualified order may be invalid even as between the parties.
Q. What will prevent a retirement order from being
"qualified"?
A. An order will not be "qualified" if it grants any type or form of
benefit, or any option, not otherwise provided under the plan, or
results in a plan having to pay increased benefits.
Q. In a QDRO, what do the terms "participant" and "alternate
payee" mean?
A. These are terms used in QDROs and other retirement orders.
"Participant" refers to the spouse who is an employee or former
employee of the plan sponsor, and "alternate payee" refers to a
nonemployee spouse.
Under ERISA, an alternate payee is "any spouse, former spouse,
child, or other dependent of a participant who is recognized by a
domestic relations order as having a right to receive all, or a portion
of, the benefits payable under the plan with respect to such
participant." An alternate payee, under a QDRO, is treated as a plan
beneficiary.
Q. How do pension or retirement assets get divided by a
QDRO in a divorce?
A. QDROs can and must be drafted to provide for differing payment
types depending upon the type of plan involved. One type of
payment is a "shared payment." A second type of payment is a
"separate interest."
Q. What is a "shared payment" and how does it work?
A. One type of payment available is a "shared payment," whereby
the QDRO seeks to divide only actual payments made with respect
to the participant under the plan. Under a shared payment
approach, only the participant's stream of income is divided and the
alternate payee is not actually given a portion of the actual
retirement benefit. Therefore, the alternate payee's right to receive
payment is dependent upon the participant's receipt of payments
under the plan and he or she will not receive a distribution unless,
and until, the participant is in pay status. Accordingly, QDROs
providing for shared payments are typically entered in cases where
the participant is already receiving payments under the plan.
Q. What is a "separate interest" payment and how does it
work?
A. Under a "separate interest" QDRO, the participant's actual
retirement benefit is divided, and the alternate payee is permitted to
receive a portion of the retirement benefit to be paid at a time and
in a form different from that chosen by the participant. A separate
interest QDRO is often preferred where the order seeks to divide a
pension as part of the marital property as opposed to providing for
support payments. A separate interest award is permitted by
Maryland law whether the participant spouse's interest in the plan is
vested or unvested at the time of divorce.
Q. What happens when one spouse puts nonmarital funds
into an IRA of the other spouse?
A. One spouse's creation of an individual retirement account or IRA
solely in the other spouse's name but primarily with the contributor
spouse's nonmarital funds may indicate the contributor spouse's
intent to make a gift to the recipient spouse, and to relinquish
equitable interest in the funds. The contributor spouse's conduct
may support classification of the IRA as the recipient spouse's
nonmarital property upon divorce.
Q. After divorce, can one spouse collect Social Security
benefits based on the other's record?
A. If a divorce occurs after at least 10 years of marriage, you can
collect retirement benefits based on your former spouse's Social
Security earnings record if you are at least age 62 and if your
former spouse is entitled to or receiving benefits. If you remarry,
you generally cannot collect benefits on your former spouse's
earnings record unless your later marriage ends (whether by death,
divorce, or annulment). Get more information at
www.socialsecurity.gov.
Q. How does divorce and remarriage affect Social Security
survivor's benefits?
A. If your divorced spouse dies, you can receive benefits as a
widow/widower if the marriage lasted 10 years or more. Benefits
paid to a surviving divorced spouse who is 60 or older will not affect
the benefit rates for other survivors receiving benefits.
In general, you cannot receive survivors benefits if you remarry
before the age of 60 unless the later marriage ends, whether by
death, divorce, or annulment.
If you remarry after age 60 (50 if disabled), you can still collect
benefits on your former spouse's record. When you reach age 62 or
older, you may get retirement benefit on the record of your new
spouse if they are higher. Your remarriage would have no effect on
the benefits being paid to your children.
Get more information at www.socialsecurity.gov.
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| Meiselman & Helfant, LLC |
29 Wood Lane, Rockville, Maryland 20850
| Call 301-279-8840 |
| Serving Bethesda, Chevy Chase, Gaithersburg, Germantown, Kensington, Potomac, Rockville, Silver Spring, Wheaton, Montgomery County, Prince George's County, Frederick County, and Howard County. |
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