The money stream is flowing again: After two years of stagnant or, worse, shrinking revenue, the 50 largest independent broker-dealers report their annual revenues rebounded last year - significantly in many cases.
Driven by a robust stock market and strong demand for mutual funds, annuities and other products, Financial Planning's 26th annual ranking of the Top 50 independent broker-dealers saw a median increase in revenue of 13.2%, with 13 of the firms on this year's list posting year-to-year growth of more than 20%.
Lincoln Investment Planning was the fastest-growing broker-dealer with a 63.6% leap in revenue. Lincoln was followed by Triad Advisors (50.2%), American Portfolios Financial Services (43.8%) and CFG/H. Beck (42.9%). All four firms are midsize B-Ds with 2010 revenues of less than $100 million.
But the next two fastest-growing firms are Top 10 B-Ds. Wells Fargo Advisors Financial Network's revenue jumped 40.9% to $434.2 million and Cambridge Investment Research - which was the fastest-growing B-D on last year's list with a modest 3.2% revenue rise - posted an increase of 36% to $339.3 million. Cambridge fell just short of the Top 10 this year, settling in at No. 11.
The industry turnaround is dramatic: Just three FP50 firms increased their top line last year, and the year before was only slightly better, with 11 firms reporting positive revenue growth. By comparison, 44 of the Top 50 broker-dealers on this year's list reported growth. Of the Top 50, six reported lower revenues and three firms were new to the list, meaning 41 firms enjoyed growth.
"Some of last year's strength resulted from the weakness of the two previous years," says Cambridge Chairman and CEO Eric Schwartz. "It's easier to post good numbers when you're coming back from bad years. As stocks continued to climb in 2010, recurring revenues from fees and trails received a huge boost. Also, investors' confidence rose as stocks came back, which helped reps acquire new assets."
It's likely that some of the money that had been tucked away in bank CDs found its way into investment products last year. It's also likely that continued economic uncertainty helped some B-Ds.
"Economic difficulties led to layoffs and retirements," says Art Grant, CEO and president of Cadaret Grant. "Those events in turn led to rollovers and repositioning assets." Money moving to rollover IRAs from 401(k)s might have wound up being managed by financial advisors affiliated with independent B-Ds, and the same is also true for buyout packages.
"In addition," says Grant, "there is disillusionment with wirehouses and their well-publicized troubles in the past several years. That presents opportunities for mainstream, conservative, planning-oriented advisors."
HOW THEY'RE RANKED
The FP50 is compiled by Financial Planning, which each year surveys independent broker-dealers about their annual revenues, as well as commission and fee revenue. They're also asked about total payouts, production of their reps, commissions and fee-based product details and other related information.
Industry giant LPL Financial, with 2010 revenue of roughly $3 billion, again tops the FP50. And Ameriprise, with revenue of $2.5 billion, again ranks as No. 2. The two giants each generated twice the revenue of Raymond James Financial Services, which ranked No. 3 with a bit more than $1 billion in revenue. While the very top of the list was unchanged from last year, there was a big shake-up was visible elsewhere in the rankings.
Commonwealth moved to fourth place from fifth, leapfrogging AXA Advisors. MetLife Securities advanced to sixth from seventh, passing Securities America. Wells Fargo moved into the top 10, improving to ninth from 12th, while Cambridge just missed, jumping four slots to 11th from 15th.
"For the past three or four years, we've been changing our culture so that it's not just focused on transactions," says John Brett, senior vice president of the MetLife Broker-Dealer Group. "We're taking a more holistic approach, which has provided the momentum for growth."
John Peluso, president of Wells Fargo Advisors Financial Network, credits his firm's growth to its "unique market position" - the company's resources combined with local business ownership, the reputation of the Wells Fargo brand, and the leverage gained by relying on a wide range of products and services.
In the new survey, no firm moved up more than four slots. Cambridge's rise to 11th from 15th place was matched by Waddell & Reed (to 16th from 20th) and American Portfolios (40th from 44th). Heading the other direction, Investors Capital lost the most ground, dropping to 48th place from 40th. Investors Capital, though, posted a 9.9% revenue gain in 2010. Six firms in the FP50 acknowledged that revenues fell last year, including double-digit dips at M Holdings Securities (-10.7%) and PrimeVest Financial Services (-12.3%).
RISING REVENUE
The top four firms on the FP50 dominated the growth statistics. LPL, Ameriprise, Raymond James and Commonwealth posted growth rates ranging from 18.7% to 23.4%, far better than the FP50 median growth rate of 13.2%.
A large part of the FP50's revenue increases came from mutual funds. The firms boosted mutual fund revenues by about $600 million, with a median increase of 16.9%. Nonetheless, Brett says, "Many investors are still feeling uncertain about mutual funds after the market losses of 2008 to 2009."
By comparison, revenues from individual securities increased around $20 million, with a median gain of just 2%. "These figures may indicate that investors are tiptoeing back into the market," says Craig Israelsen, an associate professor at Brigham Young University, who compiled the FP50 survey results for Financial Planning. "Funds offer diversification, which may reduce volatility. Investors' confidence seems to be building slowly."
Revenues from annuities also rose by a total of about $440 million for the FP50. The median gain was 12.4%. Variable annuity revenues were up sharply while fixed annuities fell, probably reflecting stock market strength last year as well as the prevalence of low yields.
Many investors are looking for guarantees, says Brett, "which they can find in variable annuities, along with upside potential. A variable annuity is a product fit for these times."
Bill Dwyer, president of national sales and marketing at LPL, concurs: "They can be powerful instruments to help clients meet their accumulation, distribution and insurance needs," he says. "However, advisors may have to spend a great deal of time rebalancing client's portfolios within their variable annuities." LPL just launched a fee-based VA that allows advisors to handle asset reallocation more efficiently, Dwyer notes.
On the insurance side, total revenues rose by nearly 2%. The FP50 list revealed upticks in average life, disability and long-term care sales.
COMPENSATION, FEES GROW
The survey data indicate that commission revenues from annuities, insurance and some mutual fund sales grew in 2010. But fee revenues grew faster. Only seven firms posted growth of more than 30% in commission revenues, led by Triad's 45.1% gain. Five firms saw commission revenues fall. But 22 FP50 firms saw fee revenues rise by more than 30%, led by a 94.2% spurt at Lincoln Investment Planning. Uvest (down 4.9%) was the only firm to report a drop in fee revenues.
Some of the larger firms get a large portion of their revenues from fees. "Often, bigger reps are less transaction-oriented," says John Rooney, managing principal for Commonwealth in San Diego. "If they are looking for a broker-dealer with a sophisticated fee-based platform, they might consider us. So we tend to wind up recruiting reps who have a substantial fee-based practice."
At Commonwealth, fees account for nearly 58% of total revenues. "Our heavy exposure to fee-based business helped us in 2010," Rooney says. "As markets went up, so did our asset management fees. We estimate that our revenues grew by 10% to 12% from the market's rise, and the rest of our growth came from new assets."
Rooney isn't worried that a strong tilt toward asset management fees will automatically create a revenue drop if the markets retreat and asset values shrink. "Back in 2008 and 2009," he says, "when the stock market lost heavily, it was the transaction-oriented people who were hurt. Transactions dried up. Our fees dropped but they kept coming in. About 65% of our revenues are recurring, from asset management and trail fees. It's very nice to have that dependable cash flow."
That's not to say that Commonwealth is resigned to the volatility of asset values and management fees. "We're increasing our emphasis on absolute return products such as managed futures and hedge funds," Rooney says.
"Some people might say that stocks and bonds are fully priced now, so we're helping our reps find alternatives," he adds. Indeed, Commonwealth reported that hedge fund revenues surged to $1.4 million last year from about $40,000 in 2009, and revenues from managed futures doubled the hedge fund tally.
Among other alternatives, real estate is not popular, according to Rooney. "Many clients already have accumulated real estate assets and they don't think that market will snap back right away," he says. "We are doing a lot of business in other areas not correlated to stocks and bonds, such as precious metals, commodities, pipelines and so on."
While fees increase in importance, commissions remain vital to many B-Ds. Triad, for instance, saw a 45% increase in revenues from commissions last year, along with a 66% jump in revenues from fees.
"Our advisors tend to have hybrid practices," says Nate Stibbs, senior vice president of business development at Triad. "About 90% of our advisors own their own separate RIAs. Under their RIAs, they can do fee-based, comprehensive financial planning. Simultaneously, under our broker-dealer, they can do alternative investments, insurance and other products to round out what they offer to their clients."
RECRUITING UPS AND DOWNS
The boost in revenues from fees and commissions came despite fewer reps at many firms. In fact, the median for the FP50 was a 2.2% decline in total reps and a similar drop in producing reps. Of the 47 firms reporting 2009 and 2010 rep counts, 26 reported a decline while two others increased the total by less than 0.5%. Among the 10 largest B-Ds, five firms had fewer reps, while one had a modest increase. Six B-Ds reported declines of 10% or more, with Uvest (-29.4%) losing the most on a percentage basis.
Still, some firms managed to add to their rep rolls in 2010. Nine B-Ds, in fact, reported double-digit increases, led by midsize Lincoln Investment Planning (up 55%), Triad (36.7%) and CFG/H. Beck (31.2%). Among the largest B-Ds, significant increases in total reps were posted by Wells Fargo (15.3%) and Cambridge (13.1%).
Firms that did not load up on new reps in 2010 may have been digesting prior efforts. "We added relatively few reps last year," says Commonwealth's Rooney, "but we had a spectacular recruiting year in 2009. It took a while for those reps to get settled in and for their assets to transfer, and the results really showed in 2010."
Dick Averitt, chairman and CEO of Raymond James, estimates that one-third of last year's revenue growth at his firm can be attributed to market strength and about two-thirds to new advisor recruiting - new assets - combined with existing advisors' increased productivity. Similarly, Cambridge's Schwartz estimates that half of his company's revenue growth last year came from new recruits. But recruiting producing reps is only half the story, retaining them as they increase production is the other.
"Our revenue growth has resulted from our recruiting success and our advisor retention," Stibbs says. "We've added several large firms. In addition, capital markets have improved so some of our advisors have been able to participate in opportunities offered by our parent company, investment banking firm Ladenburg Thalmann. Last year, for example, some of our advisors put clients into IPOs of some stocks and closed-end funds."
How does a midsize B-D such as Triad compete against larger firms? "Larger broker-dealers often want their reps to be under the corporate RIA," Stibbs says. "They want to have more control over their business. In our model, most reps own their own RIAs and we give them access to several institutional platforms for managing money. Our reps have a great deal of flexibility."
Schwartz and MetLife's Brett see recruits coming from insurers' broker-dealers. They want "a more holistic approach," Brett says. To help lure them, MetLife has introduced investment advisory programs, including one featuring mutual funds with a minimum investment requirement of only $10,000.
"We're expanding our efforts to train our reps for the Series 65 exam," Brett adds. Passing that test enables reps to qualify as investment advisors and offer fee-based financial planning, in addition to any commissions earned from products such as annuities and life insurance.
For the reps who made it through the hard times of 2008 and 2009, the FP50 survey confirms 2010 was a very good year. Total payout increased at all but four firms. The median increase was 14.3%. Nine FP50 firms increased total payout by more than 30%, led by MetLife, which reported a 91.8% jump. Other large B-Ds with sizable payout increases include Wells Fargo (41.8%) and Cambridge (36.5%).
As might be expected with more payout dollars and fewer reps at many firms, the average payout per producing rep rose substantially. The median figure was 18.4%; MetLife's average payout per producer soared by nearly 108% and Securian Financial Services reported an increase of almost 80%. Although the four largest B-Ds didn't come close to No. 5 MetLife's rise, they reported that average payouts rose anywhere from 16.9% (Ameriprise) to 25.3% (Raymond James).
Seven FP50 firms reported a decrease in average payout. The largest drop (26.3%) occurred at Lincoln Investment Planning, which, as noted, substantially increased its number of producing reps.
WHAT'S NEXT?
"One of our initiatives this year is to help our advisors identify and acquire target firms," Stibbs says. "With backing from our parent company, we can provide financial help." Both Stibbs and Commonwealth's Rooney point to efforts to expand fee revenues from employer-sponsored retirement plans. "We're moving to extend the fiduciary model to qualified plans," Rooney says. "Advisors can be fiduciaries. Some advisors already do a large business in 401(k)s, 403(b)s and so on, but we're attempting to get others to understand the opportunities there." The greatest opportunities for advisors and their B-Ds may come from pre-retirees.
"Historically," says LPL's Dwyer, "financial firms have targeted potential clients in the 55 to 64 age range. As a group, they've bought their extra cars and put extra rooms on the house and put their kids through college. Once they reach their mid-50s, they're at their peak earning years, ready to start investing heavily for retirement."
While that's always been the case, the current crop of pre-retirees is especially attractive, Dwyer adds. "There are more of them now and going to be even more, as the oldest baby boomers reach that age group. In addition, they've been contributing to defined contribution plans for nearly 30 years. Now they'll be responsible for managing that money and they're seeking advice." LPL will give advisors time to tap this mother lode of prospective clients by offering centralized marketing support and turnkey asset management, Dwyer says.
Perhaps most of all, leading independent B-Ds will emphasize the policies that helped them get through the financial crisis of 2008 and 2009 and emerge with a successful 2010. "Although our advisors are open to considering private deals, hedge funds and such," Grant says, "they have very little interest in anything that isn't verifiable and predictable. Our due diligence process is guided by common sense rather than wishful thinking and crystal ball forecasts."
"We have tried to provide practical guidance for current conditions," Grant says. "In addition to reminding people that there are no magic, secret solutions to meeting goals, we have encouraged advisors not to chase yield because yield with safety doesn't exist right now. Our advisors are winning clients and building business by counseling patience and diversification."
Patience and diversification helped independent B-Ds get through the last market meltdown and probably will continue to be a winning strategy. If the economic rebound stays on track and the markets avoid a significant retreat, continuing growth would be a reasonable expectation for the independent B-D industry.
Ameriprise Financial: Training Powerhouse
Ameriprise has attracted more than a 1,000 advisors to its franchise division since 2008, including powerhouse teams like Josh Brown and Ron Reinas, who arrived from Merrill Lynch this spring.
Besides the financial strength of the company, Don Froude, president of the No. 2 broker-dealer's personal advisors group, sees its investment in training and continuing education as a big draw for established planners. "We offer advisors more ways to make their practice efficient than any of our competitors," he boasts.
Last winter, the firm hosted training sessions, attended by 2,500 advisors, to introduce its new Opportunity Manager software, which searches client records to identify potential buyers for all of the firm's products and services - and ranks the most likely sales. "Advisors love it because it helps them stay focused and fill any gaps for clients," Froude says.
At the same time, advisors are steadily moving over to the popular ThomsonOne platform, which produces performance reports for clients. The transition should be complete next year. With the introduction of new ETF and bond portfolios last year, the firm's Active Portfolios family now includes close to 50 options.
Separately, the corporate parent backed a settlement between broker-dealer Securities America and investors who'd lost money in private placements before announcing that Securities America was for sale. The company was not a big part of Ameriprise's overall business, notes Chip Roame, managing principal at Tiburon Strategic Advisors. (Figures from Securities America are not included in the survey data for Ameriprise.)
- Temma Ehrenfeld
AXA Looks to Boost Efficiency
For two years, AXA Advisors has been recruiting more reps from wirehouses as well as independent planners to its hybrid model. Today, three-quarters of the company's reps sell brokerage products along with life insurance and annuities.
"As an insurance company, we're conservative. What attracts reps is you get a 152-year history and a solid technology platform and innovative products," says AXA Advisors President Christine Nigro.
To boost efficiency, the No. 5 broker-dealer in this year's FP50 has introduced paperless statements and confirmations. In the next few months, it will roll out a tool that pulls in data from other firms for consolidated performance reports. Its open architecture platform already allows planners to work with managed accounts from other brokerages.
The broker-dealer is a growing source of revenue for AXA Equitable Life Insurance and won more clients and assets last year. "We remain in the top five because of our strategy of building relationships," Nigro says. "There's no hard sell. We don't believe in the idea that you did a bad job if you hang up the phone and haven't made a sale." As AXA focuses on fee-based and larger accounts, Nigro thinks revenue from fees could beat commission-based revenue by the end of the year.
- Temma Ehrenfeld
LPL Tries to Tie it All Together
LPL Financial, the top broker-dealer in the FP50, is big and looking to get bigger.
By the end of 2013, Tiburon Strategic Advisors predicts LPL will have 20,000 reps, up from 11,924 on this year's list. "What we've done differently from most broker-dealers and custodians is concentrate on being in one business. We don't own funds. We only offer advice support. This makes us a true melting pot," says Bill Dwyer, president of national sales and marketing.
LPL's goal is to help advisors serve more clients. Assuming lower returns, as most observers predict, planners will need to win and manage twice as many clients as they did in the 1990s if they want their revenues to grow 20% a year, according to Dwyer's estimates.
The firm's technology should help, Dwyer says. All of the company's systems are tightly integrated and all new offerings must work well with its proprietary software.
LPL has launched a fee-based variable annuity platform, expanded its portfolios to include a variety of ETFs, and introduced portfolio rebalancing software as well as Salesforce.com, a leading tool for communication with clients.
The decision to offer a fee-based variable annuity platform came out of experience in the downturn, Dwyer says. Planners who had discretion over client accounts could rebalance them in minutes - a much more efficient practice than calling each client to seek permission. Since annuities appeal to people approaching retirement, Dwyer expects sales to rise. To help ensure LPL can grab the business of baby boomers, the company bought National Retirement Partners, a broker-dealer that offers advisors a host of tools to work with pension plan sponsors. Among other big moves, the company went public last year and recently announced the purchase of Concord Wealth Management, which provides technology for trusts at institutions.
Going forward, Dwyer says, "We're going to keep on taking advisor feedback and enhancing the tools that allow planners to spend time with clients."
- Temma Ehrenfeld
Commonwealth Offers Deep Support
Commonwealth Financial Network has the industry's highest average production, which the company says is not just a result of having great advisors, but also giving them great support.
"We not only offer the most effective technology platform," says Commonwealth managing principal John Rooney, "we also back it up with the highest home-office-staff-to-advisor ratio." Strong support systems and strong company results helped Commonwealth move into fourth place on this year's FP50 list, leapfrogging AXA.
A year ago, Commonwealth enhanced its proprietary system to manage client information for day-to-day tasks as advisors move increasingly toward digital workflow. The firm has ranked near the top of Tiburon Strategic Advisor's technology rankings for many years. "It's a well-run firm," notes Chip Roame, managing principal at Tiburon.
Commonwealth took top place last year in a survey of financial advisors by J.D. Power and Associates, winning the best score for "all of the key drivers of satisfaction," says David Lo, J.D. Power's director of investment services. Key factors included compensation, products for clients, customer service for advisors and services to minimize the time advisors spend on compliance paperwork.
"We see a big drop in satisfaction when advisors have to spend more than 15% of their time on compliance duties," Lo says. On average, 62% of advisors say they've kept their compliance time under that threshold, Lo reports, compared with 68% at Commonwealth.
In the next six months, Commonwealth plans to roll out a new tool for designing and rebalancing portfolios. The software will allow planners to "quickly and efficiently design and trade models," Rooney says. The system will have the ability to lock in positions, establish cash buffers and rebalance without churning.
- Temma Ehrenfeld
Raymond James Focuses On Productivity
Raymond James Financial Services, the No. 3 broker dealer on the FP50, has about the same number of advisors as five years ago, but it's a much better group now than in 2006. "We're recruiting more productive financial advisors," says CEO Dick Averitt. Indeed, 512 advisors produced more than $500,000 in revenue in 2010 compared with 363 in 2006.
It's been a good year for the brand. In April, The Wall Street Journal ranked seven Raymond James analysts as Master Stock Pickers in their Best on the Street survey. Fortune included the firm in its World's Most Admired Companies list. And in Smart Money's recent survey of full-service brokers, Raymond James leapfrogged Edward Jones for the top spot. The survey weighed such factors as the performance of recommended stocks and customer satisfaction. Raymond James was one of only two surveyed with a model portfolio that did better than the S&P 500 in 2010.
The company's success is building on itself. Averitt reports that existing clients have been bringing Raymond James more business, a trend he credits in part to good communication during the economic crisis. The number of client accounts has increased 10% since the market bottom in March 2009. And the company, which loses less than 1% of advisors with above-average production to rivals, is providing tools to make them even more productive.
This spring, the company gave its advisors access to all client data on iPads, and the company introduced a platform that eliminated fees on nearly 50 mutual funds. Later this year, Raymond James plans to waive fees for cash accounts that offer direct deposit and give clients more flexibility managing their money online.
- Temma Ehrenfeld
Pershing, NFS a Clear Choice for Many B-Ds
As the last few, volatile years have demonstrated, the corporate world is more interrelated than ever. And, when doing business today, managers need to kno?w not only their vendors, but also their vendors’ vendors, as well.
This year, Financial Planning asked the independent broker-dealers it surveyed for its annual FP50 ranking to name their preferred clearing firm. Of the 46 B-Ds that responded, 25 cited Pershing, six named National Financial Services and seven others said they use both Pershing and National Financial. Why did so many top independent broker-dealers pick these two clearing firms for such a critical partnership?
Size matters, of course, because a clearing firm should have the resources to service a variety of B-Ds and all manner of affiliated reps. Pershing, a subsidiary of the Bank of New York Mellon, and National Financial, a Fidelity Investments company, are backed by parents with ample resources.
Good pricing is a factor, too, but price alone is not enough. “Although we are satisfied with our financial arrangement, that can’t be the driving issue in choosing a clearing firm,” says Art Grant, CEO and president of broker-dealer Cadaret Grant, which partners with Pershing.
What really drives the 50 largest broker-dealers when choosing a clearing firm is competence, transparency, reliability, responsiveness, flexibility to adapt to a changing environment and, says Grant, “an opportunity to be involved in the clearing firm’s planning for the future. We appreciate access to the company’s leaders and their willingness to work with us in a collaborative way. We get all that and then some with Pershing as our partner.”
John Brett, senior vice president of the MetLife Broker-Dealer Group, says he constantly gets calls from other clearing firms, but sticks with Pershing. “The senior leadership at Pershing is very responsive to our needs,” he says, “and the product solutions Pershing provides are state of the art.”
At MetLife, the broker-dealer group includes a diverse set of advisors. “Some are independent,” says Brett, “and others might work out a MetLife branch. They all come to us with questions and requests for advice, which we’ll pass on to Pershing, when appropriate. Pershing has the capability to address these concerns, from all types of advisors.”
Brett cites “order blasting” - placing of orders across multiple accounts - as an example of Pershing’s responsiveness. “Reps might want to move many of their clients out of one mutual fund and into another,” he says. “We heard from the field that our people wanted this to be done swiftly and effortlessly. We passed on these concerns to Pershing and worked together with them to develop a system that has been very effective.”
B-Ds that rely upon National Financial say the firm is also a responsive partner. “Today, more than ever, it is critical to have a clearing partner that not only understands your unique business model, but can also deliver the most competitive menu of products, services and technology solutions available,” says Nate Stibbs, senior vice president of business development at Triad Advisors.
Since Triad’s inception in 1998, NFS has been its clearing firm. “Many factors led to our decision to work with National Financial,” Stibbs says. “Above all, we were attracted by the firm’s reputation as a leader in the clearing business and its culture as an organization. In our opinion, you get out of your clearing relationship what you put into them, and over the years we have invested significantly in building our relationship with NFS.”
“We have enjoyed consistent, long-term growth in our business,” says Stibbs, “and part of our success has come through National Financial’s comprehensive platform of practice management tools, technology systems and clearing capabilities.” Stibbs cites NFS’ recent introduction of Streetscape Fee-Based Tools, which provide advisors with a broad range of portfolio management applications, including modeling, block trading and rebalancing.
Wayne Bloom, CEO of Commonwealth Financial Network, also cites a solid partnership. “We have a strong, close relationship with the team at NFS,” he says, “particularly with Sanjiv Mirchandani, its president. We have the utmost confidence in the proficiency with which NFS handles every trade, statement, report and countless other transactions for clients every day.”
Bloom asserts that the Fidelity brand resonates extremely well with investors. That means Commonwealth advisors can expect a positive reaction when they can point out the Fidelity connection to clients. “With so much disruption in the marketplace these days,” says Bloom, “it’s important to field a team that can offer stability, financial wherewithal, and an ability to work well together for the benefit of both financial advisors and their clients.”
While most broker-dealers choose a single clearing firm, some B-Ds feel they have more options by using more than one. “We remain fiercely committed to remaining independent,” says Amy Webber, president and COO of Cambridge Investment Research. “We do business with both National Financial and Pershing, two firms that offer the strength, stability and flexibility we need to be able to achieve our goals and stay true to our core values. Our advisor partners are given the choice when it comes to clearing firms. This allows our advisors to do business in a way that is best for them and their clients.”
It’s unclear whether the trend will continue. However, given the testimony of B-D executives, there appears to be no shortage of solid clearing choices.
- Donald Jay Korn
