At Blue Sky Research Services I use my 30+ years of brokerage and investment consulting industry experience to assist investment managers and broker dealers in identifying actionable research services and critical resources for investment decision making. I am an institutional broker and am familiar with all aspects of third-party soft dollar brokerage 28(e).

Sales and marketing of institutional brokerage services and third-party (independently produced) investment research to trust companies, mutual funds, and pension investment advisors. The territory I covered was the western region: Denver west (including Hawaii) and Canada to the Mexico border. (see, http://www.midwood.com/ )

I joined Lynch Jones & Ryan in early 1997 as a V.P. of Institutional Sales covering institutional asset managers on the eastern seaboard from Hartford, CT to Memphis, TN including Baltimore and Washington D.C. Prior to 1997 LJR had specialized in institutional "directed brokerage", and LJR’s clients were primarily plan sponsor organizations which "directed" brokerage in commission recapture arrangements. The Institutional Sales Group was a new sales and marketing effort at LJR. Our objective was to sell third-party produced investment research to institutional asset managers. In September of 1998 the U.S. Securities and Exchange Commission issued its Inspection Report on the Soft Dollar Practices of Broker-Dealers, Investment Advisors and Mutual Funds. This "Inspection Report" failed to acknowlege that institutional advisors' brokerage arrangements with full-service brokerage firms facilitate the generation of significant levels of undisclosed soft dollar credits which institutional advisors exchange for unidentified full-service brokers' "services". The SEC's failure to acknowledge soft dollars in bundled undisclosed full-service brokerage arrangements was a competitive 'spike through the heart" of the third-party institutional brokerage industry. [This lack of acknowledgement signalled the continued unequal enforcement of Section 28(e) of the Securities Exchange Act of 1934, as it relates to soft dollar arrangements]. Shortly after the release of the Inspection Report LJR disbanded its Institutional Sales Group and restructured the company. Within a very few months LJR was sold to Instinet, LLC. (see, http://www.sec.gov/news/studies/softdolr.htm)

Hoenig Group was an institutional agency brokerage firm (did not act as principal in transactions). I was Regional Director of Institutional Sales. My region was the Western U.S. including Hawaii and Alaska. I presented and sold independently produced investment research services and investment research technology to investment advisors at bank trust departments, mutual fund complexes, and hedge funds. I was an institutional broker with Series 7 and 63 Registrations. The institutional advisors paid for the services purchased using soft dollar mark-ups on brokerage transactions directed to Hoenig's trading desk. After Ron Hoenig's death, Hoenig Group was acquired by Investment Technology Group (ITG).

At Wilshire Associates I performed functions similar to those I had at SEI Financial Services. I consulted with institutional investment advisors managing equity portfolios for trust companies, pension plans and mutual funds and I recommended Wilshire Associates portfolio constructon and analytic tools as solutions to investment management challenges. I performed as a registered Series 7 Series 63 broker offering institutional brokerage services through Wilshire's brokerage subsidiary. Wilshire's institutional services group was disbanned after the crash of '87. See > http://www.wilshire.com/

Summer employment while in college. I continued working on the beach some week-ends and on vacations from my career employment until 1987.

During my tenure with SEI Financial Services I worked as a financial services salesperson selling managed investment products to institutional advisors, and I also sold investment research, portfolio consulting and analytic tools to pension plans, bank trust departments, and mutual fund asset managers. I performed as a registered Series 7 Series 63 broker offering institutional brokerage services through SEI's brokerage subsidiary. (see, http://www.seic.com/enUS/index.htm )