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Couples will no longer be able to use file and suspend and restricted applications, increasing the importance of considering each spouse’s longevity.
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A special note of thanks goes out to Luke Delorme of the American Institute for Economic Research (www.aier.org), William Reichenstein of Social Security Solutions (www.socialsecurity solutions.com) and Judith Ward of T. Rowe Price (www.troweprice.com) for answering detailed questions about the rule changes and claiming strategies, as well as providing feedback on and suggested edits for this article.
Included in the Bipartisan Budget Act of 2015 are provisions phasing out two Social Security claiming strategies.
Beginning in May 2016, married couples will no longer be able to file for and then suspend receiving benefits for the purpose of making their spouses eligible to take spousal benefits, and singles will no longer be able to file and suspend to have the flexibility of retroactively claiming benefits. Applications to restrict the claiming of benefits to just spousal benefits are limited to those who were at least age 62 as of the January 1, 2016. The ability to use restricted filings will be completely phased out in 2023 when the last of those eligible to use restricted filings turn age 70.
The changes simplify the decision process for claiming retirement benefits by removing two options. At the same time, the changes highlight the importance of calculating the various expected lifetime income streams from claiming at various ages. Often, the later in life that benefits are taken, the higher the lifetime income stream will be. The downside of postponing the date when benefits begin is the risk of not living long enough to pass the breakeven date. The breakeven date is the month when the cumulative benefits from delaying the claiming date matches the cumulative amount that would have been received by having claimed earlier.
The trade-off means that both individuals and couples should consider their expected longevity as well as the risk of dying sooner or later than expected. The challenge of deciding whether to claim earlier or later also highlights the role of Social Security as a retirement income annuity that provides a hedge against a longer-than-expected life span.
Social Security is a stream of income paid monthly to those who qualify. An individual’s Social Security retirement benefit is based on their primary insurance amount (PIA). The PIA is based on the highest 35 years of earnings (limits on maximum income for any one year exist and earnings before age 60 will be indexed.) In addition, married individuals may be eligible for benefits based on their spouse’s record. Reduced monthly benefits can start as soon as age 62. Full benefits can be claimed at full retirement age (FRA). Full retirement age is 66 for those born between 1943 and 1954, increasing up to age 67 for those born in 1960 or later. Benefits can further be increased by delaying them up to age 70.
As explained in “Social Security Basics” (William Reichenstein and William Meyer, October 2013 AAII Journal), the reduction in benefits from claiming prior to full retirement age is 5/9% per month for the first 36 months plus 5/12% per month for months 37 through 48 for someone with a full retirement age of 66. If benefits are delayed until after full retirement age, the increase is 2/3% per month for each month benefits are delayed until age 70. This means a person with a full retirement age of 66 will incur a 25% reduction in benefits by claiming at age 62 and a 32% premium by waiting until age 70.
Put another way, assume a person will receive $1,000 in retirement benefits (PIA) at a full retirement age of 66. If this person claims early at age 62, the PIA will be reduced to $750. If the same person waits until age 70 to claim benefits, the PIA will be $1,320—76% higher. This difference in monthly benefits will continue until a person dies (or the person’s spouse dies, if the surviving spouse has a lower monthly benefit, based on their own earnings record.)
This is why, even with the changes, Luke Delorme, a research fellow with the American Institute for Economic Research (AIER), says “Delaying Social Security benefits until age 70 in order to receive delayed retirement credits is still one of the best deals around.”
Also, see the box “The Advantage of Delaying” below, written by William Reichenstein of Social Security Solutions: It illustrates how the choice of when to claim impacts the expected lifetime benefits. It shows the difference in total benefits that a hypothetical couple—Tom and Nancy (who is four years younger than Tom)—would receive if Tom claimed at age 70 instead of age 66.
Suppose Tom’ s PIA is $2,000, his full retirement age is 66, and life expectancy is low at 75. Nancy, his wife, is four years younger, and she has a life expectancy of 90. Nancy has a lower PIA of $700. After Tom’ death, Nancy will continue receiving Tom’s benefits, while benefits based on her earnings record will cease.
Consider two strategies: Tom begins his benefits at full retirement age or delays his benefits until age 70. Based on their life expectancies, if Tom begins his benefits at full retirement age of $2,000 per month, then they would receive $672,000 in total benefits based on Tom’s earnings record ($2,000 per month x 12 months x 28 years from when Tom turns 66 until Nancy’s death when Tom would have been 94). Alternatively, if Tom delays his retirement benefits until 70, then they would receive $2,640 per month, where the $640 in additional monthly benefits reflect four years of delayed retirement credits. Their total benefits based on Tom’s record would be $760,320, ($2,640 per month x 12 months x 24 years from when Tom turns 70 until Nancy’s death when Tom would have been 94). By delaying benefits until age 70, their expected lifetime benefits would be $88,320 higher.
The lesson is that the higher earner should base his or her starting date on the age he or she would be when the second spouse is expected to die. Even though Tom has a short life expectancy, it pays for him to delay his benefits until 70 because benefits based on his record will last until the second spouse dies.
(These numbers do not reflect cost-of-living adjustments, but they do reflect the lifetime purchasing power of the benefits and are fair comparisons. If inflation is, say, 1% each year then actual benefits would increase 1% each year, but so would prices. So, their purchasing power in terms of today’s dollars would remain the same. Due to today’s low interest rates, the non-COLA adjusted numbers are also the approximate present values.)
—William Reichenstein, Social Security Solutions
Social Security benefits are paid monthly until death. As such, the payment of benefits is akin to an inflation-adjusted annuity. A stream of cash flow is guaranteed and will be increased in the future in accordance with estimated inflation (via cost-of-living adjustments). Longevity risk is borne by the government and not the retiree.
Annuities are priced, in part, based on actuarial tables. The underwriters attempt to estimate the length of time payments will be made to help determine how much should be charged for the contract.
Social Security benefits, from the standpoint of claiming, are similar. The longer a person lives, the longer the period of time Social Security benefits will be paid. Thus, the monthly benefit increases the longer benefits are delayed, because the payments will have to be paid out over a projected shorter period of time. As such, Social Security is considered to be approximately actuarially fair: Assuming a single individual lives an average life span, cumulative benefits are about the same regardless of the claiming date. This fact brings about two potential considerations when claiming benefits. The first is the odds of having a shorter- or longer-than-average life expectancy. Married couples need to consider the potential longevity of both spouses. The second applies to couples: Benefits can be thought as a first-to-die and second-to-die annuity if there is a survivor benefit.
Survivor benefits are paid to the spouse with the lower earnings record (“Low”) if Low’s PIA is less than that of the spouse with the higher earnings record (“High”) and Low outlives High. To keep things simple, assume both spouses are the same age and file at the same time and Low’s PIA is less than half of High’s. If Low lives longer than High, it is in the best interest of High to postpone claiming as long as possible to maximize the survivor benefit income stream that Low will receive after High dies. If Low should die first, High still receives the largest monthly benefit based on his or her earnings record by delaying benefits. The survivor benefit is the higher PIA of the two spouses.
Longevity comes into play when the breakeven age is calculated. The breakeven age is the age at which the cumulative benefits from delaying benefits matches the cumulative benefits that would have been received had Social Security benefits been claimed earlier.
Reichenstein gives an example of a same-aged, one-earner couple with a life expectancy of age 85 for High and age 91 for Low. They have reached full retirement age of 67. If High begins benefits at 67, then Low can begin spousal benefits at that time. If High delays benefits until 70, then Low would not be able to begin spousal benefits until that time. If High were to start benefits at age 70 instead of age 67, one spouse (Low in this example) would have to live to beyond 88 years and nine months to realize the higher lifetime income from doing so under the revised claiming rules. Assuming a monthly PIA of $2,600 for High, this difference equates to approximately $7,500 extra every year that Low lives past the breakeven point. In other words, if Low were to live five additional years past age 88 and 10 months, approximately $37,500 more in Social Security benefits would be received if High delays claiming benefits until 70. See Reichenstein’s box “Claiming at 67 or 70 for a One-Earner Couple” below for more details on this. (Cost-of-living adjustments are excluded from the example.)
The data below shows the difference in annual and lifetime benefits for a one-earner couple. Both spouses were born on January 2, 1960 and have full retirement age of 67. The working spouse (High) has a PIA of $2,600. The non-working spouse (Low) only qualifies for the spousal benefit. The strategies assume High claims at his full retirement age of 67 or delays until age 70. The life expectancies are 85 for High and 91 for Low.
| Claim at Age 67 | Claim at Age 70 | Difference Between Claiming at 67 and 70 | |||
| Age | $2,600 PIA | Spouse | $2,600 PIA | Spouse | |
| 67 | $2,600 | $1,300 | $46,800 | ||
| 68 | $2,600 | $1,300 | $93,600 | ||
| 69 | $2,600 | $1,300 | $140,400 | ||
| 70 | $2,600 | $1,300 | $3,224 | $1,300 | $132,912 |
| 71 | $2,600 | $1,300 | $3,224 | $1,300 | $125,424 |
| 72 | $2,600 | $1,300 | $3,224 | $1,300 | $117,936 |
| 73 | $2,600 | $1,300 | $3,224 | $1,300 | $110,448 |
| 74 | $2,600 | $1,300 | $3,224 | $1,300 | $102,960 |
| 75 | $2,600 | $1,300 | $3,224 | $1,300 | $95,472 |
| 76 | $2,600 | $1,300 | $3,224 | $1,300 | $87,984 |
| 77 | $2,600 | $1,300 | $3,224 | $1,300 | $80,496 |
| 78 | $2,600 | $1,300 | $3,224 | $1,300 | $73,008 |
| 79 | $2,600 | $1,300 | $3,224 | $1,300 | $65,520 |
| 80 | $2,600 | $1,300 | $3,224 | $1,300 | $58,032 |
| 81 | $2,600 | $1,300 | $3,224 | $1,300 | $50,544 |
| 82 | $2,600 | $1,300 | $3,224 | $1,300 | $43,056 |
| 83 | $2,600 | $1,300 | $3,224 | $1,300 | $35,568 |
| 84 | $2,600 | $1,300 | $3,224 | $1,300 | $28,080 |
| 85 | $2,600 | $3,224 | $20,592 | ||
| 86 | $2,600 | $3,224 | $13,104 | ||
| 87 | $2,600 | $3,224 | $5,616 | ||
| 88 | $2,600 | $3,224 | -$1,872 | ||
| 89 | $2,600 | $3,224 | -$9,360 | ||
| 90 | $2,600 | $3,224 | -$16,848 | ||
|
Before the changes, the breakeven age was 82.5. After the recent changes, the breakeven age is almost 88 years and 9 months. If there is an expectancy of one spouse living beyond this age, High should delay claiming until age 70. Source: William Reichenstein, Social Security Solutions. |
|||||
The risk, of course, is that neither High nor Low make it to or live past this breakeven age. If both spouses have shorter life-span expectancies, then it can make sense to claim benefits sooner rather than later. Health and genetics (e.g., how long one’s parents lived) need to be taken into account when claiming. At the same time, realize that longevity is considered to be a “right-tail” risk in the world of finance: The longer one lives, the more money they will need. This why economists like annuity contracts—they transfer longevity risk from the individual to a third party.
(One big difference between Social Security and commercial annuities is that the government is not contractually obligated to pay benefits. Congress has the legislative ability to change benefits, alter the amount of Social Security benefits eligible for taxation, raise the ages at which benefits can be claimed and alter the amount of income subject to the FICA tax, which funds Social Security. The political willpower to do any of these things is a different issue and beyond the scope of this article. As far as the risk of insolvency is concerned, the Social Security and Medicare Boards of Trustees predicts benefits would be reduced by 25% starting in 2034 if nothing is done to shore up Social Security reserves before then.)
The 2015 budget bill took away two options that could be used for claiming Social Security: “file and suspend” and restricted applications. Both had allowed for more flexibility and a greater margin of error when filing.
Starting in May 2016, the file-and-suspend claiming strategy for spousal benefits will be disallowed. This strategy allowed a person to file a claim for benefits and then immediately suspend it, while still leaving spousal benefits and retroactive benefits available as options. For example, the High spouse could file for benefits at age 66 and then postpone taking benefits until age 70. This allowed High to maximize the PIA, while making Low eligible to claim spousal benefits. See the box “File and Suspend: Before and After the Change” also by Reichenstein below for an example.
The following example illustrates how the file-and-suspend strategy was used and how it will be changed.
Lynn has a primary insurance amount of $2,000 and turned 66 in August 2015. Al, her husband, will turn full retirement age of 66 in August 2016, and has a PIA of $1,600. Prior to the recent rule changes, Lynn was going to file and suspend her benefits when Al turned 66 in August 2016. She would then begin her own benefits at 70 of $2,640, which reflects four years of delayed retirement credits. Since Lynn filed for her benefits (even though she suspended them), Al could have filed a restricted application for spousal benefits of $800, half of her PIA, beginning August 2016. Four years later when Al turned 70, he planned to switch to his own benefits of $2,112, which reflects four years of delayed retirement credits.
The new rules do not allow Lynn to file and suspend benefits beyond April 29, 2016. Thus, if she does not file and suspend her benefits until August 2016, as originally planned, then Al would not be eligible for spousal benefits until Lynn actually begins her benefits at age 70, when Al turns 69. She must file for her benefits for Al to be eligible for spousal benefits. Thus, Al would lose three years of spousal benefits from age 66 through 68.
In this case, Lynn should file and suspend her benefits by April 29, 2016. She would still receive $2,640 per month in benefits at 70. However, this would allow Al to make a restricted application for spousal benefits at his full retirement age of 66. To repeat, if Lynn fails to file and suspend by April 29, 2016, then Al cannot begin spousal benefits until she actually starts her benefits. To change the example slightly, if Lynn attains 66 in March 2016 then she can file and suspend any time from March through April 29, 2016. But she will not be able to file and suspend after that date.
—William Reichenstein, Social Security Solutions.
Restricted applications allow a married person to file for spousal benefits only at full retirement age if their spouse has already filed (e.g., a working wife could file for only spousal benefits when she turns 66 if her husband has already filed for benefits based on his own earnings record). Restricted applications allowed a person to begin receiving spousal benefits, while postponing the date at which they claimed on their own earnings record.
The Bipartisan Budget Act of 2015 contained language requiring spouses take the highest benefit they are eligible for. The law reads, “If an individual is eligible for a wife’s or husband’s insurance benefit…in any month for which the individual is entitled to an old-age insurance benefit, such individual shall be deemed to have filed an application for a wife’s or husband’s insurance benefits for such month.” In other words, a spouse cannot receive spousal benefits while delaying claiming on his or her own earnings record until age 70 if his or her PIA is equal to or greater than one half of the other spouse’s PIA. Using a hypothetical same-age couple named Bob and Mary, if Mary’s PIA is $1,500 and Bob’s is $2,000, Mary would be ineligible to claim the lower spousal benefit (one half of Bob’s, or $1,000) at full retirement age while postponing benefits based on her own earnings record.
The rules still allow someone to suspend benefits at full retirement age or later and earn delayed retirement credits when benefits are unsuspended, such as at age 70. At the same time, the law prevents individuals from claiming benefits on their spouses’ earnings record if the other spouse is not currently receiving benefits. The law states: “In the case of an individual who requests that such benefits be suspended under this subsection, for any month during the period in which the suspension is in effect…no monthly benefit shall be payable to any other individual on the basis of such individual’s wages and self-employment income; and…no monthly benefit shall be payable to such individual on the basis of another individual’s wages and self-employment income.”
In other words, once a person files for Social Security, the maximum benefits will be paid based on what he or she is eligible for. Spousal benefits will be paid if High is already receiving benefits and Low (whose PIA is less than one half of High’s) files. If neither spouse has filed, benefits will be paid on the individual’s earnings record. A married person is “deemed” as having filed for both individual and spousal benefits if the other spouse has already filed. Going back to Bob and Mary, Mary is deemed as filing based on her earnings record because her PIA is greater than the spousal benefit. If Mary’s PIA was $700 instead, she would be deemed as filing for the spousal benefit and would receive a benefit of $1,000. [Technically, if Mary files at full retirement age, the Social Security Administration gives her her own PIA of $700 plus spousal benefits of $300 ($1000 – $700), for a total of $1,000.] See Reichenstein’s box “The Impact of Suspending Benefits” below for another example.
Consider a same-age couple (Joe and Jan) who were born on January 2, 1954, or later and have one child. Joe has a PIA of $2,000 and Jan’s is $700. Their full retirement ages are 67.
Joe begins benefits at 62 of $1,400 per month, which makes Jan eligible for her own plus spousal benefits and makes their child eligible for a child’s benefit. Jan’s own benefits would be $490, [70% of $700], and her spousal benefits would be $195, [0.65 x ($1,000 – $700)], for total monthly benefit of $685, where 70% and 65% are the self benefit fraction and spousal benefit fractions for someone age 67 beginning benefits at 62, and $1,000 is half of Joe’s PIA.
At full retirement age, Joe suspends his benefits and restarts them at age 70. During the suspension period, Jan would not be eligible for spousal benefits because they are based on Joe’s earnings record, but she could continue her own benefits of $490. Their child would not be eligible for child’s benefits based on Joe’s earnings record. In addition, Joe would not be eligible to file a special application for spousal benefits based on Jan’s PIA because he was born on January 2, 1954, or later. When Joe restarts his benefits at 70, he would receive $1,736, ($1,400 x 1.24, where 1.24 reflects three years of delayed retirement credits).
—William Reichenstein, Social Security Solutions
The changes simplify the claiming decision by removing two options. The new rules make determining when to take benefits largely a claim now or claim later decision for married couples. (It has generally been this way for singles.) Even so, the decision of when to claim remains a complex one. Assuming a person or a couple is able to voluntarily choose when to retire, forethought and the willingness to calculate cumulative differences in claiming at one age versus another is required.
Single individuals have the easiest decision. Divorced persons ineligible to claim benefits based on an ex-spouse’s earnings record should delay claiming as long as possible given their health and expected longevity. Those who have a reasonable expectation of not living past 80 can claim earlier, though delaying results in higher lifetime benefits at age 80 and beyond versus claiming earlier. Waiting until age 70 to claim ensures higher lifetime benefits for those who live into their 90s or longer.
Married couples face a bigger challenge because two benefit amounts are in play: that of the high earner and that of the low earner. The reason is not only the survivor benefit, but also the spousal benefit. The lower-earning spouse is able to receive benefits based on the higher-earning spouse’s record if Low is at least 62 years of age. (Special rules apply if a child who is under the age of 16 or disabled is being cared for. See the Social Security’s website at www.ssa.gov for more information.)
If both spouses have enough work history to qualify for Social Security benefits, Low has the flexibility of claiming early while High delays. Doing so may make sense even if Low’s PIA is less than half of High’s PIA. Judith Ward of T. Rowe Price explains, “If a lower-earning spouse can file on their own work history, the other spouse can delay for as long as possible, since they are the higher earner. This maximizes the survivor benefit. Then when the higher earner files for their own benefit, the spouse who had been receiving the smaller benefit may get a bump up in monthly income if the spousal benefit (half of High’s PIA at full retirement age) is higher than their own.”
The Bipartisan Budget Act of 2015 eliminated two options for claiming Social Security benefits. The act did, however, include two windows for certain individuals and couples to take advantage of the older rules. In doing so, the law segmented people into one of three age groups:
Here’s a summary of how the rules apply to each of the three age groups:
Source: “Social Security Claiming Strategies After the Recent 2015 Changes,” Social Security Solutions.
She added, “In single-earner households there is less incentive for even the higher earner to delay because the non-working spouse depends on that income as well.” The timing of when income is needed is key because once High files, Low will receive benefits on High’s earnings record. Unlike the old rules, effective May 2016 High can no longer file for benefits and then suspend them in order to allow Low to start receiving benefits. In a couple with one non-working spouse, Low will only receive benefits when High does. (Those who file and suspend before the May 1, 2016, deadline can take advantage of the older rules.)
As long as the spousal benefit is a consideration, the numbers on the breakeven age must be calculated. For a same-aged couple with PIAs of $2,600 and $600, the breakeven age for High postponing until age 70 instead of claiming at age 67 is almost 85 years and 10 months, assuming High lives to age 85 and Low lives to age 91. If Low has a shorter life span, then claiming earlier is more beneficial. If Low has a longer life span, then Low is penalized by High’s decision not to wait until age 70. These scenarios are based on numbers calculated by Reichenstein.
A big loss for married couples is the flexibility that the file-and-suspend strategy provided. File and suspend gave couples the upside of receiving income sooner and a bigger survivor benefit. Now, couples must weigh the need for income sooner against the potential longevity of the longer-living spouse. Depending on the age differences between spouses, their individual PIAs and anticipated longevity, the optimal age(s) for claiming will vary. There is simply no substitute for running the numbers based on various claiming dates to determine what claiming strategy is best for a specific couple.
There are some general guidelines, however. The rule of thumb to delay the claiming date up to age 70 still holds, but with some exceptions. Delaying maximizes the survivor benefit for married couples. If Low is younger, then it is often better for High to file when Low’s full retirement age is reached as opposed to delaying until age 70. This will give Low the full spousal benefit and often gives the couple greater income. (This will not be an option if the age difference is greater than eight years. In such a situation, it usually makes sense for High to delay to age 70, which would maximize Low’s survivor benefit.) If Low’s PIA is greater than 50% of High’s but still less than High’s, then it can make more sense for both spouses to delay until age 70 (or at least for High to) since the spousal benefit is no longer an option, but the survivor’s benefit is. If both High and Low do not expect to live much past the age required to realize the higher income of delaying, then it can make sense to claim benefits earlier.
Again, the key is to run the numbers based on various claiming dates to determine what strategy makes the most sense. PIAs, longevity expectations and ages all will influence the outcome. The more likely it is for the surviving spouse to pass the breakeven age, the more it makes sense to delay filing. When in doubt, it may make more sense to assume a longer life span than a shorter one.
At the time of publication, there is still time to take advantage of file and suspend and restricted applications for those meeting specific age requirements. Individuals and couples who attain at least age 66 as of the end of April 2016 can file applications for Social Security benefits and immediately suspend them. Married individuals who were born prior to January 2, 1954, can file restricted applications until they turn 70.
The ability to file and suspend ends 180 days after the enactment of the Bipartisan Budget Act of 2015. The exact deadline is uncertain because May 1, 2016, is on a Sunday. As of the date this article was sent to the printer, the Social Security Administration had yet to announce whether or not it would extend the deadline to Monday, May 2, given the weekend deadline. The law itself does not list a precise deadline either. Rather it says, “The amendments made by this subsection shall apply with respect to requests for benefit suspension submitted beginning at least 180 days after the date of the enactment of this Act.”
Given this, it is prudent to treat the deadline as being April 29, 2016, until an actual deadline is announced. If at all possible, file and suspend before that date or at least set up an appointment to meet with the local Social Security office to file before that date. You want to avoid any potential difficulties due to a large number of individuals and couples filing in the days leading up to the deadline.
Filing and suspending benefits provides flexibility in claiming benefits. For example, consider a hypothetical couple, Mike and Mary. If Mike files and suspends at his full retirement age (FRA) of 66, Mary can claim spousal benefits when she reaches her full retirement age based on Mike’s earning record. In the meantime, Mike can wait until age 70 to take his benefits, which will increase due delayed retirement credits. In order to file and suspend, a person must have attained age 66 by the May 1, 2016, deadline.
Restricted applications are another useful tool. If Mike files or files and suspends, and Mary was born prior to January 2, 1954, she could file a restricted application for just spousal benefits at full retirement age. This would give the couple income now, while giving Mary four years to postpone taking benefits based on her own earnings record. This strategy increases the couple’s lifetime earnings stream.
The deadline for file and suspend is key because if Mike suspends taking his benefits in June 2016 instead of April, Mary’s spousal benefit will stop being paid until Mike reinstates his benefit. Under new law, benefits are only payable on a spouse’s earnings record if benefits are being paid to the primary spouse. It will still be possible to suspend benefits after May 1, 2016, thus earning delayed retirement credits, but all benefits based on the person’s earnings record will stop being paid.
Those born on January 2, 1954, or later can still use restricted applications to create a similar strategy, however. If both spouses have earnings records and one spouse files for benefits based on their own earnings record, the other spouse, if at least full retirement age, can restrict their application to only spousal benefits. This allows the second spouse to delay claiming on their own earnings record until they reach full retirement age or older. At age 70, the benefit paid to the second spouse will be the higher of spousal benefit or PIA, adjusted upward to reflect delayed retirement credits.
Those (both married and single) born on or before April, 30, 1950, should file and suspend before the deadline even if they intend to begin taking benefits sooner rather than later. Given the forthcoming changes, filing and suspending now gives the greatest amount of flexibility in determining what the best claiming strategy is. Married individuals born between May 1, 1950, and January 1, 1954, who “attained” at least age 62 by the end of 2015, will attain an age no older than 65 as of the start of May and are not married to a spouse who will have attained age 66 by the May 1 deadline will only be able to take advantage of a restricted application.
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