FINANCIAL LITERACY 

Enhancing the 

Effectiveness of the Federal 

Government’s Role

Statement of Alicia Puente Cackley, Director 

Financial Markets and Community Investment

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

For Release on Delivery 

Expected at 2:30 p.m. EDT

Thursday, April 26, 2012

GAO-12-636T

United States Government Accountability Office

GAO
United States Government Accountability Office

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

April 26, 2012

FINANCIAL LITERACY

Enhancing the Effectiveness of the Federal 

Government’s Role

Why GAO Did This Study

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 

addition to the important roles played 

by states, nonprofits, the private 

sector, and academia, federal 

agencies promote financial literacy 

through activities including print and 

online materials, broadcast media, 

individual counseling, and classroom 

instruction.

This testimony discusses (1) the 

federal government’s role in promoting 

financial literacy, including GAO’s role;

(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 on

prior and ongoing work, for which GAO 

reviewed agency budget documents, 

strategic plans, performance reports, 

websites, and other materials; 

convened forums of financial literacy 

experts; and interviewed 

representatives of federal agencies 

and selected private and nonprofit 

organizations.

While this statement includes no new 

recommendations, in the past GAO 

has made a number of 

recommendations aimed at improving 

financial literacy efforts.

What GAO Found

The federal government plays a wide-ranging role in promoting financial literacy. 

Efforts to improve financial literacy in the United States involve an array of public, 

nonprofit, and private participants, but among those participants, the federal 

government is distinctive for its size and reach and for the diversity of its 

components, which address a wide range of issues and populations. At forums of 

financial literacy experts that GAO held in 2004 and 2011, participants noted that 

the federal government can use its “bully pulpit,” convening power, and other 

tools to draw attention to the issue, and serve as an objective and unbiased 

source of information about the selection of financial products and services. In 

prior work, GAO cited a 2009 report by the RAND Corporation in which 20 

federal agencies self-identified as having 56 federal financial literacy programs, 

but GAO’s subsequent analysis found substantial inconsistency in how different 

agencies defined and counted financial literacy programs. Based on a more 

consistent set of criteria, GAO identified 16 significant financial literacy programs 

or activities among 14 federal agencies, as well as 4 housing counseling 

programs among 3 federally supported entities, in fiscal year 2010. The 

Comptroller General has initiated a multi-pronged strategy to address financial 

literacy issues. First, GAO will continue to evaluate federal efforts that directly 

promote financial literacy. Second, it will encourage research of the various 

financial literacy initiatives to evaluate the relative effectiveness of different 

approaches. Third, GAO will look for opportunities to enhance financial literacy 

as an integral component of certain regular federal interactions with the public. 

Finally, GAO has recently instituted a program to empower its own employees, 

which includes an internal website with information on personal financial matters 

and links to information on pay and benefits and referral services through its 

counseling services office and a distinguished speaker series.

Having multiple federal agencies involved in financial literacy offers advantages 

as well as risks. Some agencies have long-standing expertise and experience 

addressing specific issue areas or populations, and providing information from 

multiple sources can increase consumer access and the likelihood of educating 

more people. However, the participation of multiple agencies also highlights the 

risk of inefficiency and the need for strong coordination of their activities. GAO

has found that the coordination and collaboration among federal agencies with 

regard to financial literacy has improved in recent years, in large part as a result 

of the Financial Literacy and Education Commission. At the same time, GAO has 

found instances of overlap, in which multiple agencies or programs, including the

new Bureau of Consumer Financial Protection, share similar goals and activities, 

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 

that it continue its efforts to delineate its financial literacy roles and 

responsibilities vis-à-vis those of other federal agencies with overlapping 

responsibilities. 

View GAO-12-636T. For more information, 

contact Alicia Puente Cackley at (202) 512-

8678 or cackleya@gao.gov. 
 

Page 1 GAO-12-636T 

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

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.

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.

4

 

1

GAO, Financial Literacy: The Federal Government’s Role in Empowering Americans to 

Make Sound Financial Choices, 

In 

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 2 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 

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 

Background 
 

Page 3 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 

public, nonprofit, and private participants. Among those participants, the 

federal government is distinctive for its size and reach, and for the 

diversity of its components, which address a wide array of issues and 

populations. At our forum last year on financial literacy, many participants 

said that the federal government had a unique role to play in promoting 

greater financial capability.9

 

5

Harris Interactive Inc., prepared for The National Foundation for Credit Counseling, The 

2010 Consumer Financial Literacy Survey Final Report (April 2010).

They noted that the federal government has 

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 

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. 

The Federal 

Government Plays a 

Wide-Ranging Role in 

Promoting Financial 

Literacy 
 

Page 4 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

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.

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.

11

 

10

In prior work, we cited a 2009 report that had identified 56 federal 

GAO-05-93SP. 

11According 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 5 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.

 

12GAO, 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. 

13Our 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 6 GAO-12-636T 

Having multiple federal agencies involved in financial literacy efforts can 

have certain advantages. In particular, providing information from multiple 

sources can increase consumer access and the likelihood of educating 

more people. Moreover, certain agencies may have deep and longstanding expertise and experience addressing specific issue areas or 

serving specific populations. For example, the Securities and Exchange 

Commission has efforts in place to protect securities investors from 

fraudulent schemes, while the Department of Housing and Urban 

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 

 

14GAO-11-614. 

Having Multiple 

Federal Agencies 

Involved in Financial 

Literacy Offers 

Advantages as Well as 

Risks 
 

Page 7 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 governmentchartered 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 8 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 

the need to focus federal financial literacy efforts on initiatives that work. 

Relatively few evidence-based evaluations of financial literacy programs 

have been conducted, limiting what is known about which specific 

methods and strategies are most effective. Financial literacy program 

evaluations are most reliable and definitive when they track participants 

over time, include a control group, and measure the program’s impact on 

consumers’ behavior. However, such evaluations are typically expensive, 

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 

 

15The 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.

Program Evaluation 

and the Bureau of 

Consumer Financial 

Protection May Offer 

Avenues to Enhance 

Effectiveness 
 

Page 9 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 10 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)
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