The Veterans Administration issued Proposed Rules on January 23, 2015, in the Federal Register (Net Worth, Asset Transfers, and Income Exclusions for Needs-Based Benefits), that would impose a penalty for transfers during a look-back period. The VA proposes to define ‘‘fair market value’’ as the price at which an asset would change hands between a willing buyer and willing seller who are under no compulsion to buy or sell and who have reasonable knowledge of relevant facts. However, the VA also intends to include as a transfer for less than fair market value any asset transfer to or purchase of any financial instrument or investment that reduces net worth and would not be in the claimant’s financial interest were it not for the claimant’s attempt to qualify for VA pension by transferring assets to or purchasing such instruments or investments.