SSA proposed NICS rule

For some retirees, who might not be able to manage their own financial affairs, their gun collection may be a major asset, owned not so much for use as weapons (which is the focus of the government obviously), but as keepsakes, heirlooms, collectibles, and investments, the same as other personal property.

UPDT
Following the link to the NRA posting, they lay out the conditions:
Five factors.
1. Social Security benefits based on Disability
2. and a Disability on the "Mental Disorders Listing of Impairments"
3. and the mental impairment is the beneficiary's primary diagnosis code
4. and age between 18 and retirement
5. and payments handled by a fiduciary because the beneficiary is seriously impaired.

"... Concerns were initially raised by a report in the Los Angeles Times that SSA would follow the lead of the Department of Veterans Affairs by broadly reporting all beneficiaries receiving payments whose funds were disbursed to another individual on the beneficiary’s behalf. This prompted congressional inquiries, to which SSA replied that the plan would not apply to all beneficiaries assigned representative payees. ..."

danez71

Quote:
Originally Posted by jr45 View Post
They are not given the opportunity to what I just mentioned prior to losing their rights.

Yes they can and it was cited from the link several times in this thread in the following posts:

In post #2 I cited it from the text .

Referenced / cited twice in post # 29 (in which I even referenced the page #s in the text so you can read it for yourself)

Stated again in post# 31

And again in post #62



The information referenced and or cited 5 times in this thread.

I even tried to spoon feed you by referencing the page #'s in the documents.


All they have to do is not have some one else manage their affairs and the prohibition doesn't even come into play.

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Many SSDI and SSI recipients do not choose to have a representative payee. SSA decides that these people require a representative payee to manage the money they receive monthly. Consequently for many people who do have a representative payee it is not a simple matter of just not having someone else manage their monthly benefit. It requires petitioning SSA to have the requirement of having a representative payee removed. Evidence must be submitted and an administrative process followed.

I also only see in the links a process to appeal a decision to report them to NICS, not the ability to present their own evidence or refute evidence used by SSA before they are reported to NICS. About 58% of SSDI or SSI recipients receive their benefits after being turned down by SSA and appealing successfully to the ALJ, Appeals Council or ultimately federal court. A 58% reversal rate for decisions which are appealed hardly instills confidence in decisions made at the administrative level to determine that people should be reported to NICS and be denied a constitutional right without a hearing.

jr45 said:

Sigh. Show me where the beneficiaries are offered relief "prior" to losing their rights? The program of relief is offered after the ajudication has occured that barred them IAW 18 USC 922. I really hope there is a method for these folks to seek relief "prior" to being reported to NICS.

.

Click to expand...

What?!?!? Are you being serious?


How can you get 'relief' 'prior to' to something happening?

If it hasn't happened yet, of course, you cant get relief yet.


You're just talking in circles now.



Its simple really.

This is only for metal issues.
You apply.
There is an evaluation process based on medical and/or legal criteria.

If you get approved, then a separate step starts; that of determining if you can manage your own affairs.

If you can not manage your own affairs, (its not a matter if you voluntarily choose to have someone manage your affairs as noted above) you may become prohibited.

If you become prohibited, there is a process for you to appeal all the way to the circuit court level.


Its really not that hard to understand; that is, if you ever take time out of arguing about something you clearly have little to no knowledge of and read it.

heyjoe said:

Many SSDI and SSI recipients do not choose to have a representative payee. SSA decides that these people require a representative payee to manage the money they receive monthly. Consequently for many people who do have a representative payee it is not a simple matter of just not having someone else manage their monthly benefit. It requires petitioning SSA to have the requirement of having a representative payee removed. Evidence must be submitted and an administrative process followed.

I also only see in the links a process to appeal a decision to report them to NICS, not the ability to present their own evidence or refute evidence used by SSA before they are reported to NICS. About 58% of SSDI or SSI recipients receive their benefits after being turned down by SSA and appealing successfully to the ALJ, Appeals Council or ultimately federal court. A 58% reversal rate for decisions which are appealed hardly instills confidence in decisions made at the administrative level to determine that people should be reported to NICS and be denied a constitutional right without a hearing.

Click to expand...

ETA: I missed the part were you said "prior"


Look a little harder. Maybe start about pg 23 through around page 28.

Section 101(a)(2)(A) of the NIAA requires a Federal agency that makes any adjudication related to the mental health of a person to establish a program that permits a person to apply for relief from the firearms prohibitions imposed by 18 U.S.C. 922(g)(4). We propose to allow a person who is subject to the Federal mental health prohibitor because he or she meets the criteria in § 421.110(b) to apply for relief from the Federal firearms prohibitions imposed as a result of our adjudication.
We propose to provide these individuals with a process by which they can apply for relief from the Federal firearms prohibitions and a means to submit evidence for us to consider .

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After the applicant submits the evidence required under the rules, a decision maker who was not involved in finding that the applicant’s benefit payments must be made through a representative payee would review the evidence and act on the request for relief. We would notify the applicant in writing of our action regarding the request for relief.

Click to expand...

ETA: I missed the part were you said "prior to" being reported.



In regards to that, you go through an evaluation process. If they determine that you meet the criteria to force you to have someone manage your affairs, you may get reported.

Once that determination has been made that you can not manage your affairs, then you can appeal.

During the evaluation process, all you have to do is show that you can manage your own affairs and you wont get to the point of being reported.

I just read a list of mental conditions SSA give benefits for, one of them is anxiety. While I can see how schizophrenia (another one on the list) could make it dangerous for a person to own a gun, anxiety is pretty hard to see.

old lady new shooter said:

I just read a list of mental conditions SSA give benefits for, one of them is anxiety. While I can see how schizophrenia (another one on the list) could make it dangerous for a person to own a gun, anxiety is pretty hard to see.

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On the surface, it mat seem overzealous but when you read the requirements, you can see that it needs to be quite severe in order to meet the criteria.


The isn't for the run of the mill 'I get anxiety when Im running late'.


This would be for someone that has anxiety so great that even after being treated, the Dr. certifies that they can not work because they meet the criteria (below).

And then after than, separately, they have to be determined that they can not manage their own affairs. Then they may be reported as a prohibited person.

12.06 Anxiety-related disorders: In these disorders anxiety is either the predominant disturbance or it is experienced if the individual attempts to master symptoms; for example, confronting the dreaded object or situation in a phobic disorder or resisting the obsessions or compulsions in obsessive compulsive disorders.

The required level of severity for these disorders is met when the requirements in both A and B are satisfied, or when the requirements in both A and C are satisfied.

A. Medically documented findings of at least one of the following:

1. Generalized persistent anxiety accompanied by three out of four of the following signs or symptoms:

a. Motor tension; or

b. Autonomic hyperactivity; or

c. Apprehensive expectation; or

d. Vigilance and scanning; or

2. A persistent irrational fear of a specific object, activity, or situation which results in a compelling desire to avoid the dreaded object, activity, or situation; or

3. Recurrent severe panic attacks manifested by a sudden unpredictable onset of intense apprehension, fear, terror and sense of impending doom occurring on the average of at least once a week; or

4. Recurrent obsessions or compulsions which are a source of marked distress; or
5. Recurrent and intrusive recollections of a traumatic experience, which are a source of marked distress;

AND

B. Resulting in at least two of the following:

1. Marked restriction of activities of daily living; or

2. Marked difficulties in maintaining social functioning; or

3. Marked difficulties in maintaining concentration, persistence, or pace; or

4. Repeated episodes of decompensation, each of extended duration.

OR

C. Resulting in complete inability to function independently outside the area of one's home

Click to expand...

But again, you have to apply to even get considered for the benefits.

Then they have to determine you meet the criteria.

Then it has to be determined separately that due to your mental health condition, that not only do you meet the criteria, you ALSO can not manage your own affairs to even be considered to be reported as a prohibited person.

old lady new shooter said:

I just read a list of mental conditions SSA give benefits for, one of them is anxiety. While I can see how schizophrenia (another one on the list) could make it dangerous for a person to own a gun, anxiety is pretty hard to see.

Click to expand...

The SSA's function is not to determine whether a person is dangerous or not; Congress made the determinations in 18 USC 922(g) that people with certain characteristics or conditions should be prohibited from owning firearms.

The SSA is only interested in SSA actions that create a condition listed in 18 USC 922(g). The SSA does not issue indictments or restraining orders, convict people of crimes, issue dishonorable discharges, etc. But the SSA does determine whether people are mentally incapable of managing their own affairs (defined as a "mental defective"), so that is what the SSA looks for to report to NICS.

In 2014, the SSA had 5.6 million recipients with representative payees (determined incapable of managing their own affairs). Of that total, 3.2 million were children, 0.7 million were retirees, and 1.7 million were disabled. NICS does not deal with children, so that group is automatically excluded. The SSA is only looking for people determined to be mentally incapable of managing their own affairs, so the place to start looking is among the disabled. And not all of the disabled are mentally incapable; one of my relatives recently went totally blind and is physically incapable of managing her own affairs, but she is not mentally incapable.

But the SSA does determine whether people are incapable of managing their own affairs (defined as a "mental defective), so that is what the SSA looks for to report to NICS.

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They do that for people that have proactively sought it out from them (or are so crazy and were force to).

Show them you can balance a check book and pay your bills and BINGO, you just showed them you can manage your own affairs with the money they're sending you. Then they wont report you according to their own rules.


There is your 'relief prior to'.


Still, not difficult to understand if you take the time to read it.

ETA: My comment wasn't directed 'at' gc70 even though I used the word 'you'; which is why I didn't quote his screen name. I was only trying to clarify that they aren't on some witch hunt and automatically making you a prohibitive person with no way to avoid the prohibited status. Its quite the opposite.

danez71


They do that for people that have proactively sought it out from them (or are so crazy and were force to).

Show them you can balance a check book and pay your bills and BINGO, you just showed them you can manage your own affairs with the money they're sending you. Then they wont report you according to their own rules.


There is your 'relief prior to'.

Click to expand...

most people who have representative payees do not proactively seek to have them. Most have no idea they are going to get a representative payee until they get a letter stating that they are required to have one.
As has been pointed out to you before your characterization of what you have to do to eliminate a mandate to have a representative payee is much more involved than you are portraying it. you dont just walk into an office and show them you can balance a check book.
Also the use of the word crazy betrays your prejudice with this topic. Why do you feel that you need to answer every single post on this thread? You seem to be very emotionally invested in it.

most people who have representative payees do not proactively seek to have them. Most have no idea they are going to get a representative payee until they get a letter stating that they are required to have one.

Click to expand...

This is not true. The vast majority of folks who have a representative payee asked to have one appointed. The representative payee is usually a close relative.

ttps://www.https://www.ssa.gov/payee/faqrep.htm#&a0=0ssa.gov/payee/faqrep.htm#&a0=2

heyjoe said:

most people who have representative payees do not proactively seek to have them.

Click to expand...

I never said that. I said they proactively seek out the benefits.

heyjoe said:

As has been pointed out to you before your characterization of what you have to do to eliminate a mandate to have a representative payee is much more involved than you are portraying it.

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I don't see where any has pointed that out with any kind of reference other than, maybe, 'the NRA says it' type statement.


ETA:

said by jr45

Getting ssa to drop the representative payee is a lot more involved than just showing you can balance a check book.
https://www.ssa.gov/payee/faqbene.htm

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My comment of 'show them you can balance your check book and pay your bills' was in reference to prior to being appointed a representative payee. I have, on several occasions, pointed out that if you don't agree with their decision, you can appeal all the way to the circuit court level and have the opportunity to present your own evidence. I have not mischaracterize it. You're misrepresenting what I said just as you have been doing with the text of the document in most of this thread

heyjoe said:

.
Also the use of the word crazy betrays your prejudice with this topic.

Click to expand...

I should not have used that phrase. That was rude of me.

heyjoe said:

. Why do you feel that you need to answer every single post on this thread? .

Click to expand...

That's false, I have not.

heyjoe said:

You seem to be very emotionally invested in it.

Click to expand...

There's a few reason. A couple of which are that it bothers me when people spew out misinformation as facts in order to get support. And, my 'best friend'* of over 30 yrs is currently on meds, and was part of the system.

Based on his 1st hand experience, whats being spewed here isnt true. His biggest complaint was just working through the system to get some help; nothing about any Rights he may loose.

I recognize that his sole experience isn't the end all, be all.


However, when posters keep making intentional false statements as compared to the text in the link in order to gain support, I'll call it out every time.



* My best friend is fine with 'crazy' type comments. He has made the same type of comment it about himself. He knows who I am and what type of person I am. We have a great relationship. (I also have an employee that is bipolar, she's made similar comments about herself, in jest.)

However, no one here knows me. And, for anyone that doesn't know me, I can see how my comment could reasonably be considered callous.

If I offended anyone, I apologize.

i do not want anyone who is a vetted threat to themselves or others owning or buying guns.

The NRA lauded the passage of the NIAA:

•

Prevents use of federal “adjudications” that consist only of medical diagnoses without findings that the people involved are dangerous or mentally incompetent. This would ensure that purely medical records are never used in NICS. Gun ownership rights would only be lost as a result of a finding that the person is a danger to themselves or others, or lacks the capacity to manage his own affairs.

Click to expand...

https://www.nraila.org/articles/20080108/hr-2640


The NRA is presently whining, demagouging and pandering to Bubba now that the SSA is attempting to implement the NIAA.

i've been an NRA member for nearly 60 years. For decades i gave to the NRA until it hurt. Don't do at anymore because the NRA wants me to buy into the entire agenda of one political party. I refuse to do that. My contributions now go to another pro-Second Amendment organization.

I appreciate the discourse here, and the analysis.

There is the printed document of what the NIAA says it will do, and there is reality, where we know For A Fact that the .Gov can and will abuse, aka EPA, ATF, VA, and others avoiding public scrutiny or the media complicit in not covering it.

Worst case scenario is someone railroaded into signing up for the process and gets adjudicated. Family and friends mistakenly pressure them into doing it. They actually sign the notice they will revoke their 2A rights - remember the warnings? Be very sure there will be a separate document that will spell out the criminal penalties, a copy given to the applicant for their records, with their legal signature.

The i's will be dotted and the t's crossed. It won't happen unless and until someone wants the money MORE than their 2A rights. Or, they simply don't have the presence of mind to understand - which also brings in question how could they assess right and wrong.

We already have "sane" people who can't get the even the simpler rules right, who shoot family unintentionally, or themselves, or worse, who attempt to be cops or heroes to "save the day." And die in the attempt. An administrative procedure to collect funds from us on the basis of declaring yourself to be mentally disabled? Sounds self fulfilling.

Can family or the government abuse it? Possible. But each case has it's own risk of probability that can't and won't be like the next.

Does that make 58 million Americans in immediate danger of having their rights stripped from them? Well, they might be - for some. The reality is that with typical bureaucratic inefficiency it would take a tong time to process them while at the same time more continue to line up for the handouts. Which the ATF is doing already for some applications - by not doing them.

And if the family is complicit with the declaration as a scam, the family can hand over guns, too. A law does not prevent it. It only punishes after the fact if discovered. Laws cannot and do not prevent - this measure does in the typical manner of laws by restricting or prohibiting the legal purchase of firearms which requires a NICS check. And we already know just how many criminals bother to do that. Hence the copy of the written notice warning you to avoid purchasing firearms illegally once you say or it's determined "I'm too crazy to trust with a gun."

Of course, if you go out and get one somehow anyway - how crazy were you? Two edged sword in legal terms.

It's NOT all that some try to make out, but it IS more than some are attempting to assure us. Just because there are procedures and a process doesn't mean it will be followed in the way we expect. As the law change and different perspectives or interpretations are created new procedures might arise that could be either good or bad. Depends on your perspective.

We can't forecast the abuse, what we do know is those already adjudicated who can still go buy a gun and then use it in an act of violence should be prevented. For the most part I see it as expanding the number of names on the NICS rolls but actually doing little because so many wouldn't attempt it anyway.

It's another feel good government program that still can't stop terrorists or criminals acting out there agenda - both sane enough to get around the law in deliberate acts to show they can.

Honestly, these new rules aren't bad. At least 95% of the people who would be excluded under these rules shouldn't be owning weapons in the first place. And there IS an appeals process should you be one of the 5% who should not be on this list.

Also note that number 5, it's because they REQUIRE their payments be made through a payee because they're determined incapable of managing it themselves. A person has to be in pretty bad shape for a very long time for that. This is very different than someone who just requests their payments go through a payee.

Ultimately, I think this is overall a good rule. Part 5 really limits the people who would be affected by it. Is it perfect? No. But it is pretty darn good.

Danez71 (post 78):
This is only for metal issues.
You apply.
There is an evaluation process based on medical and/or legal criteria.

If you get approved, then a separate step starts; that of determining if you can manage your own affairs.

If you can not manage your own affairs, (its not a matter if you voluntarily choose to have someone manage your affairs as noted above) you may become prohibited.

If you become prohibited, there is a process for you to appeal all the way to the circuit court level.

Click to expand...

It sounds like this is the crux of the OPs concern. The decision is made by an administrator (bureaucrat) and his firearms are gone (unless he appeals and wins.) Although the “conditions” are laid out, there is no control over the way an administrator can interpret those criteria, especially an anti-gun administrator. The appeal is a process that can take years and thousands of dollars, something that may well be out of reach for a person on disability.

Twiki357 said:

It sounds like this is the crux of the OPs concern. The decision is made by an administrator (bureaucrat) and his firearms are gone (unless he appeals and wins.) Although the “conditions” are laid out, there is no control over the way an administrator can interpret those criteria, especially an anti-gun administrator. The appeal is a process that can take years and thousands of dollars, something that may well be out of reach for a person on disability.

Click to expand...

I can see the concern.... I even said I'm not really for it back on page 1. And then again later in the thread. IMO, this is a job for family members just like when the keys get taken from grampa because it's not safe for him to drive.

I think is was gc70 that posted some statistics that disprove jr45 in many ways.

Spreading misinformation in order to gain more opposition is just as bad as the anti doing it. And I'll call them out too.


But going back to the concern, after they're determined to be eligible for the benefits, it's evaluated separately as whether or not they are capable of managing their money.

If you have been managing your money up until that point, it's a bit ridiculous to think that there's a witch hunt going on that is going to completely ignore that fact.... all for the malicious intent of take away any of your Constitutional Rights.

If they make the determination anyway, you have 60 days to appeal before you may be reported.

Then, a different person, not connected to the initial decision, reviews it.

That's 2 times you can avoid potentially being reported as prohibited. Jr45 said you don't have any.


But I go back to, if you still have been managing your money up until then... it's going to be a tough sell to say you are not capable of doing it.

§ 421.150(a) clearly places the opportunity to request relief after the SSA's determination and reporting to NICS.

jr45 said:

You have 60 day to appeal the assignment of a representative payee when you are first determined eligible for SSA. Most recipients are already past that dead line.

Click to expand...

One point not yet discussed is that § 421.110(c) of the proposed rule says that the rule will only be applied prospectively.

(c) We will apply the provisions of this section to:
(1) Capability findings that we make in connection with initial claims on or after [INSERT EFFECTIVE DATE OF FINAL RULES] under the rules in part 404, subpart U of this chapter or the rules in part 416, subpart F of this chapter, or
(2) Capability findings that we make in connection with continuing disability reviews (including age-18 disability redeterminations under § 416.987 of this chapter) on or after [INSERT EFFECTIVE DATE OF FINAL RULES] under the rules in part 404, subpart U of this chapter, or the rules in part 416, subpart F of this chapter. We will apply the provisions of this paragraph only with respect to capability findings in which we appoint a representative payee for an individual in connection with a continuing disability review.

Click to expand...

There is a huge difference between only applying the proposed rule going forward rather than applying it immediately to all existing benefits recipients.

The last sentence in § 421.110(c)(2) is particularly significant. The SSA does periodic reviews of all disability cases, which would theoretically capture everyone meeting the five criteria in the rule within a relatively short period. However, that last sentence says that identification and reporting for existing cases will be limited to representative payee appointments in connection with a review; people who already have a representative payee before a review appear to be exempted.

"Grandfathering" existing cases with representative payees is the only way to make all of the provisions of the proposed rule fit together.

As jr45 noted, an existing representative payee case would effectively have no due process or opportunity for relief from reporting (i.e. 60 days to appeal the assignment of a representative payee). § 421.140 requires notice "At the commencement of the adjudication process", which would be impossible for cases in which the adjudication of mental incapability was made years earlier.

Limiting reporting to new claims or reviews that involve a new/contemporaneous adjudication of mental incapability addresses the question of how to ensure that everyone would have access to the full range of due process and relief provisions in the proposed rule.

ADDED

I could suggest that making the proposed rule strictly prospective shows how concerned the SSA is about fairness, but I'm wearing my cynical hat today and would instead suggest that a prospective rule entails much less work for the SSA.

Immediately reporting hundreds of thousand of names to NICS would result in the SSA being flooded with responses from recipients. Implementing the proposed rules as new cases arise will involve much less work. Only implementing the proposed rule for reviews involving new representative payee appointments will also be much easier than digging through years- or decades-old files to try to "paper" a justification for reporting cases with existing representative payees.

jr45 said:

● Third, ‘mental defective’ also does not include a person whose adjudication or commitment was imposed by a federal department or agency, and:

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A department or agency adjudication does not count if one of the factors in the following three bullets also applies.

jr45 said:

Also, on 26, SSA claims they will perform the required adjudications "for the purposes of Social Security programs..." yet will be reported to NICS as prohibiting factors.

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The purpose of the SSA adjudication is not to determine whether a person should be able to own a gun, but whether the person is capable of managing their SSA benefits. Similarly, courts judge whether people are guilty of crimes, but convictions for felonies and misdemeanor crimes of domestic violence are reported to NICS.

jr45 said:

Maybe someone can shed some light on this (page 6)


.

Click to expand...

Maybe this is a source of confusion...?

The very bottom of page 3 is the heading "Background" then starting on page 4, it goes into what has transpired to come to this point.

It talks about the Brady bill, the GCA of 68, that in 2007 congress found that the BGC system needs to be better automated.

Then in Jan 2013 the President issued a Memorandum to Federal departments to figure this out and "DOJ provided its guidance to agencies in March 2013."


The middle of page 5, but still under the "Background" heading,

To address these concerns, Congress enacted the NIAA,7 which strengthened the NICS by increasing the quantity and quality of relevant records from Federal, State, and tribal authorities accessible by the system.

Click to expand...

This 'background' info goes all the way thru page 10 and goes into explaining how the systems works now.




Starting on page 11 (this is where we should start getting worried because this is what they are proposing to change to.)

The Proposed Rule

The regulatory changes in this proposed rule fall into three general categories: (1) identifying relevant records and reporting pertinent information to the NICS, (2) oral and written notification to our title II and title XVI beneficiaries who meet the requisite criteria, and (3) establishing a program that permits our beneficiaries who meet the requisite criteria to apply for relief from the firearms prohibition imposed by 18 U.S.C. 922(d)(4) or (g)(4) by virtue of our adjudication.

Click to expand...

The bulk of the proposed rule changes goes from page 11 to about page 26; but there are still more pages of important stuff after page 26

My initial concern was triggered by the original reports saying SSA was going to follow the VA policy that affected all beneficiaries with a fiduciary.

Under the current proposal, being reported to NICS as a prohibited person has little to do with being a beneficiary with a fiduciary especially if rep payee was a voluntary choice. Even if a rep payee was imposed, that is the last of five conditions.

As the NRA-ILA posting 29 Apr 2016 points out (and did anyone else read it?) as the proposal currently stands:
Five factors.
1. Social Security benefits based on Disability
2. and a Disability on the "Mental Disorders Listing of Impairments"
3. and the mental impairment is the beneficiary's primary diagnosis code
4. and age between 18 and retirement
5. and payments handled by a fiduciary because the beneficiary is seriously impaired.

What are the odds that a person who meets the first four factors is not already reported to NICS for other reasons (such as police and court records from prior incidents resulting from their mental impairment before it was even diagnosed)?

The currently proposed rules are different from the initial reports (eg, LA Times*) that SSA would do as VA did (presume either mental health disability (2.7 million SS beneficiaries) or beneficiary with fiduciary (1.5 million SS) = prohibited person). LA Times reported SSA was drafting its policy outside public view and asked National Council on Disability, National Rifle Association and others for their reaction; they did not know and they did not like it. (NCD: "The rep payee is an extraordinarily broad brush.")

8 Jan 2008 NRA did support NIAA when "Gun ownership rights would only be lost as a result of a finding that the person is a danger to themselves or others, or lacks the capacity to manage his own affairs." I believe that was before the VA debacle. NRA did object to the 2015 report that SSA rules were being formulated outside public view and were going to follow the VA policy. I find the 29 Apr 2016 NRA response to the current SSA proposals reasonably balanced.


* http://www.latimes.com/nation/politics/la-na-gun-law-20150718-story.html
Alan Zarembo, "Obama pushes to extend gun background checks to Social Security", Los Angeles Times, 18 Jul 2015.