Pricing and Valuations

April 2013
Pricing and
Valuations
Special Report
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Editor’s Letter
Trust and Credibility
In this Special Report on Pricing and Valuations, you will
find in both the News Review (page 6) and the Virtual
Roundtable (page 8), that doubts about pricing methods,
concerns about transparency of pricing and consideration
of the credibility of pricing sources are all frequent themes
whenever pricing and valuations are our subject.
In “Hedge Funds Remain Doubtful of Evaluated Pricing
Methods,” Wells Fargo’s Daniel Johnson tells us that end-users’ comfort with
vendors’ evaluated prices is a matter of debate. Justifications of prices, Northern
Trust’s Paul Sharkey adds, cannot be delivered as a “90-page PDF.” They must be
short and to the point.
Transparency of pricing, Kerry White of BNY Mellon says in the Roundtable, is
just one important element. Her firm’s approach is to use a combination of vendors
to produce quality information. Interactive Data’s Mark Hepsworth observes that
firms are indeed “stepping up” demands on vendors for transparency. And Steven
O’Hanlon of Numerix identifies transparency as “critical for institutions,” as well.
White also points to credibility as a high priority when considering pricing
sources. To be credible, in her experience, BNY Mellon has to provide multiple
vendors’ valuations to its clients. Valuations, as SIX Financial Information’s Ian
Blance says, are a “trust business.” To be trustworthy, pricing providers must be
able to justify their methodologies, inputs and assumptions, he adds. Transparency
can also contribute to trustworthiness and credibility.
The Roundtable, and this Special Report, contain more than mere urgings to
make pricing trustworthy, credible and transparent. You will also find thoughts
and coverage about how to go about achieving these virtues.
Yours sincerely,
Michael Shashoua
Editor, Inside Reference Data
Email: [email protected] Tel: +1 646 490 3969
waterstechnology.com/ird
April 2013 3
Your source for high-quality pricing,
evaluations and reference data
Financial firms are seeking unprecedented transparency
and quality of data to manage risk and maintain
operational efficiency in the face of increasing regulation
and globalization of the capital markets.
Look to Interactive Data, an internationally renowned source
for independent, high-quality data and thought leadership.
Our award-winning pricing and reference data services
are backed by the expertise and domain experience of our
dedicated staff. And because of our focus on innovation
and investment, you can count on us to continue to offer an
expanding array of services and comprehensive data coverage
to meet your evolving needs.
For more information, visit www.interactivedata.com
or call 212-771-6565.
Contents
FEATURES
8 Virtual Roundtable
Inside Reference Data gathers
together leading industry
professionals to discuss the
latest developments in the
pricing and valuations space
NEWS
6 Hedge Funds Remain Doubtful of
Evaluated Pricing Methods
6 Derivative Partners Supplies
Valuations To EDI
7 Pricing Providers Address IFRS 13
18 Q&A
Inside Reference Data
speaks to Daniel Johnson,
vice president, valuation,
Wells Fargo Global Fund
Services, about defining data
quality in prices and quotes,
and factors in choosing sources
Compliance
7 News Download
April 2013
waterstechnology.com/ird
Pricing and
Valuations
Special Report
Sponsored by
© 2013 Incisive Media Investments Limited. Unauthorized
photocopying or facsimile distribution of this copyrighted newsletter
is prohibited. All rights reserved. ISSN: 1750-8517
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Incisive Media
32–34 Broadwick Street,
London W1A 2HG
April 2013 5
News Review
Hedge Funds Remain Doubtful of
Evaluated Pricing Methods
Although pricing and valuations vendors
believe they have become much more
transparent, some hedge funds are still
not comfortable sourcing evaluated
prices from them, but regulators increasingly favor this approach, according to
pricing and valuations data executives at
Wells Fargo and Northern Trust.
Daniel Johnson, Surrey, UK-based
vice president for valuations at fund
administrator Wells Fargo Global Fund
Services, says pricing vendors believe
they are providing much greater transparency into their methodologies
today and are very confident about the
numbers they supply. However, he says
it is “a bit more debatable” whether endusers are comfortable using evaluated
prices from vendors.
Paul Sharkey, Dublin-based vicepresident, pricing manager, at Northern
Trust, says transparency is the most
important aspect of evaluated pricing.
In the past, if a client asked for justification of a price, they would be given
an explanation in a “90-page PDF,” but
today things have changed, he added.
Nicholas Hamilton
Derivative Partners Supplies Valuations To EDI
Reference and corporate actions data
provider Exchange Data International
(EDI) has partnered with Derivative
Partners, a Swiss provider of risk
management and valuation services for
structured products, to supply valuations for a wide range of structured
products in response to demand for
more transparent valuations.
Jonathan Bloch, London-based CEO
of EDI, says regulatory initiatives such
as the Markets in Financial Instruments
Directive and the Dodd-Frank Act are
6
April 2013
increasing the emphasis on independent
valuations of portfolios. The partnership
with Derivative Partners will help EDI
satisfy the need for transparent valuations of structured products, he adds.
EDI chose Derivative Partners
because it is independent of product
providers, has a “pre-eminent” position
in Switzerland with good exchange links,
and is flexible, says Bloch. The partnership gives Derivative Partners access to
EDI’s clients and marketing capabilities.
Nicholas Hamilton
irdonline.com
News Download
Pricing ProvidersTackle
IFRS 13 Compliance
Evaluated pricing providers are working with
clients to access and manage the greater
amounts of information about prices and valuations that will be available in companies’ financial statements as a result of the International
Financial Reporting Standard (IFRS) 13, which
took effect January 1.
“The price has to come with the inputs
used to derive that price,” says Jayme Fagas,
head of evaluated pricing for the Americas
at Thomson Reuters. “It leans more toward
maximizing observable market inputs. We
have to pass along the way the price is derived
on a bond, what benchmark was used and
what spread was used—and not just what was
used but why. We have to tie it to observable
market data like actual trades.”
IFRS 13 is the International Accounting
Standards Board’s definition of fair value in
transactions. The standard requires categorization of assets and liabilities under a threetier fair-value hierarchy when reporting.
The standard isolates highly liquid bonds
from those that trade in less liquid markets,
says Milton Miyashiro, product manager for
valuations at Thomson Reuters. The fair-value
hierarchy used in IFRS 13 derives from a
previous version of the standard, IFRS 7. The
real test of IFRS 13 will be the way it issues
disclosures, according to Miyashiro.
Bloomberg Moves Fair Value
Users to BVAL
Bloomberg discontinued its legacy
Bloomberg Fair Value (BVF) bond
pricing service on January 15 in
favor of its Bloomberg Valuation
(BVAL) evaluated pricing service
for bonds, asset-backed securities
and derivatives.
Customers using Bloomberg
Fair Value pricing were required
to sign new contracts and move
to the BVAL pricing model, which
industry participants and end-user
groups say is a “forced upgrade”
that will mean higher costs.
SIX Creates European
Evaluated Pricing Team
SIX Financial Information, a pricing
and data vendor, has established a
European evaluated pricing team
in Frankfurt to provide valuations
of European assets and to support
clients in the region.
The team of four is headed by
Thomas Stumpf, head of evaluated pricing valuations Europe,
with one more member due to join
in April. The team will provide
valuations of European over-thecounter and fixed-income products for use by clients around the
world, and will also support valuations of non-European assets.
Michael Shashoua
waterstechnology.com/ird
April 2013 7
Virtual Roundtable
Pricing andValuations:
Getting the Price Right
Inside Reference Data gathers together leading industry
professionals to discuss the latest developments in
pricing and valuations
Where are innovations and improvements happening in pricing and valuations? Is it in efficiency and speed
of producing pricing, or other areas?
Kerry White, global director of product
strategy, BNY Mellon: In modern financial
markets there are many different valuation methodologies accepted for different
financial instruments. These range from
exchange-listed quotes for actual transactions to prices calculated using observable inputs for securities such as bonds
and notes, to private investments that
have neither a traded price nor a price
derived from observable inputs.
From my perspective, I’d say pricing
vendors have made significant improvements in both the speed and efficiency of
producing prices over the past five years.
We have also seen other improvements,
8
April 2013
including technological advances related
to the delivery or dissemination of prices,
and improvements in service in general.
This is evidenced by a more consultative
approach to solving problems or discrepancies, and a willingness to be a bit more
transparent about the methodologies
employed to derive prices.
Mark Hepsworth, president, pricing
and reference data, Interactive Data:
In today’s volatile markets, a pricing
vendor must deploy up-to-date technology for compiling and integrating a vast
range of market data, captured from an
array of media—such as feeds, email and
phone—on a continuous basis.
Transparency has become a major
issue for clients and Interactive Data has
made significant investments toward
irdonline.com
developing and delivering systems that
are able to display and export data in a
variety of useful and intelligible formats
that fulfill clients’ ever-growing demand
for transparency.
Our investments in infrastructure
support our reference data and evaluations services. Moving from rigid batch
processing to a new fluid, continuous
system is empowering our evaluators
to dynamically assess and adjust to
changing market conditions.
Steven O’Hanlon, president and CEO,
Numerix: There is a misperception that
standardization is reducing the complexity of pricing and valuation. The truth
is that risk measurement is increasingly
interlocked with valuations. Elements
such as funding and managing collateral
are becoming pre-trade considerations
and have an impact on pricing and valuations. To that end, there are two key
areas of focus for innovation: quantitative advancement and technology.
There are significant challenges in
adapting to new market standards—
for example, managing the complexity
in valuations by utilizing OIS for
discounting curves, or understanding
the impact across business units as to
the funding and other costs through the
lifecycle of a trade prior to trade execution. There are significant investments
being made to meet these challenges.
waterstechnology.com/ird
Mark Hepsworth,
President, Pricing and
Reference Data,
Interactive Data
+1 (212) 771 6565
[email protected]
Ian Blance, head of business development for evaluated pricing, SIX
Financial Information: Clients always
want pricing as fast as possible, and
there is constant work on improving efficiency and delivery speed for operational
purposes. However, we believe that the
main innovations in pricing and valuation
are taking place in the areas of valuation
functionality and support. This is particularly noticeable in the levels of trans-
“There is a misperception that
standardization is reducing
the complexity of pricing and
valuation. The truth is that risk
measurement is increasingly
interlocked with valuations”
Steven O’Hanlon, Numerix
April 2013 9
Virtual Roundtable
Steven O’Hanlon,
Chief Executive Officer
and President,
Numerix
+1 (212) 302 2220
numerix.com
parency that valuation users increasingly
need, and the associated requirement
to ensure that valuations are fully justifiable. There is also a lot of work being
done on improving the support process
for price requests and challenges.
How are new regulatory requirements shaping the way pricing
and valuations are conducted and
provided?
White: Regulators are shaping change in
a whole host of areas, including the way
valuations are conducted, provided and
reviewed. The adoption of FAS 157 and
the changes that resulted were good
exercises in terms of preparing for newer
requirements that have come forward
with respect to fair value. Under FAS
157, fair value is the amount at which the
asset could be bought or sold in a current
transaction between willing parties in an
active market, or transferred to an equiv-
10
April 2013
alent party, other than in a liquidation
sale. This is sometimes referred to as exit
value. Under FAS 157, it is the responsibility of the reporting entity to have a
fair value procedure or review process.
Some clients were quick to recognize that
this review process isn’t something you
can outsource or neglect. This has led to
changes in the way we interact with both
clients and pricing vendors, as owners of
those assets must now take a much more
active role in terms of pricing oversight.
Many of our asset-owner clients rely on
us—and therefore our pricing vendors—
to ensure they have the most accurate
valuations possible. With the changes to
fair value reporting requirements and
the increased scrutiny on derivatives, the
interest in ensuring quality and consistently applied credit valuation adjustments has never been stronger. The
Securities and Exchange Commission’s
(SEC) guidance on fair value pricing and
the decisions implemented by regulators in 2009 magnified the need for risk
management, transparency and independent valuations across asset classes.
Hepsworth: Actions by the Financial
Accounting Standards Board, the
International Accounting Standards
Board, the SEC and the Public Company
Accounting Oversight Board have raised
awareness of firms’ valuation responsibilities. Staff at the SEC recently highlighted
irdonline.com
“valuation guidance” as one of their top three
areas of focus for 2013. Concerns are intensifying after several high-profile valuationrelated enforcement actions—most notably,
the SEC’s December order against the independent directors of several Morgan Keegan
funds. These developments have resulted in
a renewed focus by directors on valuation
policies and procedures and due diligence.
In 2012, Interactive Data held more than
400 diligence meetings related to our evaluations process, including over 100 meetings
with directors or valuation committees.
Further, we have seen significant uptick in
use of the Vantage desktop application by
clients seeking support for ASC Topic 820.
O’Hanlon: Regulatory requirements are
driving greater complexity in the valuations process. The management of
counterparty credit risk at the trade
level is transformational in many ways.
To adequately incorporate the appropriate calculations before a trade requires a
portfolio view. The majority of institutions
did not develop their infrastructures with
these requirements in mind. Regulatory
compliance and, ultimately, operational
profitability depends on tearing down
traditional business silos and making significant investment in infrastructure to meet
these demands. As the regulatory and
market environment demands increasingly
complex calculations and the volume of
data being collected grows, so too do rising
waterstechnology.com/ird
expectations of accuracy and frequency of
calculations for analysis and reporting.
Blance: The regulatory tsunami that was
predicted in the aftermath of the financial
crisis is only now beginning to hit the pricing world. In almost every financial industry
sector, new valuations regulations, standards and guidelines are coming into force.
IFRS accounting standards, Basel III capital
rules, Solvency II regulations for insurance
companies, AIFMD for hedge funds, and so
on—all have valuation components.
While these regulations vary in target
and intent—risk, consumer protection,
and so forth—virtually all the valuations
components are focused on the use of
mark-to-market and/or objective and fair
valuations for financial instruments. This
places a much greater burden on user
firms to source such prices from vendors,
and also increases pressure on vendors to
provide greater asset class coverage using
a more robust methodology.
“Changes to fair value reporting
requirements and the increased
scrutiny on derivatives mean
the interest in ensuring quality
and consistently applied credit
valuation adjustments has
never been stronger”
Kerry White, BNY Mellon
April 2013 11
Virtual Roundtable
What are funds and firms looking
for when choosing pricing and valuations providers? Is it only transparency, or are there other virtues they
want, such as greater coverage?
White: It’s all of the above, and then
some. When choosing pricing and valuations providers, transparency is definitely key. At the same time, we are
pretty demanding in terms of coverage,
as well as flexibility. Our vendors recognize that we are unlikely to pursue a onestop shop approach to securities pricing,
because it won’t allow us to deliver the
best possible price for all asset classes to
our end-clients.
BNY Mellon caters to clients of all
stripes who invest in very diverse areas.
Consequently, we need to source prices
for them to allow them to manage and
monitor their portfolios. We work with
a diverse group of vendors in order to
deliver quality information.
“Surveys consistently show
that clients of all types assign
high value to transparency,
broad coverage across and
within asset types, reliable
delivery and, most importantly,
pricing quality”
Mark Hepsworth, Interactive Data
12
April 2013
Hepsworth: Surveys consistently show
that clients of all types assign high value
to transparency, broad coverage across
and within asset types, reliable delivery
and, most importantly, pricing quality. In
a recent Inside Reference Data webcast
poll, 58% of respondents cited transparency of a pricing vendor’s methodology
and data as the most important factor
to consider when choosing a third-party
provider, with another 27% also ranking
coverage as the most important factor.
With regard to transparency, firms are
stepping up demands for vendors to
provide security level detail on pricing “inputs”—including market and
assumptive data.
Beyond this, customers seek a detailed
understanding of specific controls, policies and procedures that vendors have
in place. These may include compliance policies and procedures, the availability of SSAE 16 reports, and business
continuity procedures. Client interest
in vendors’ business continuity planning has increased since Superstorm
Sandy, and Interactive Data’s ability to
continue providing services throughout
the extremely challenging circumstances created by the storm and its
aftermath has resonated with clients.
O’Hanlon: Transparency of the underlying models is critical for institutions
as management is required by regu-
irdonline.com
latory authorities to understand the
performance—and limitations—of the
underlying pricing models. Regulatory
agencies have established sound guidelines for institutions looking to utilize
vendor models.
Other sought-after virtues include
flexibility, using models that can cover
the most asset classes, scalability, technological advancement, open IT infrastructure and an ability to integrate
and interoperate. Institutions need flexibility to adjust the models in the ways
their traders and risk managers need,
and in turn gain regulatory approvals.
The best way to manage model risk is
to ensure all operations are utilizing the
models. Hybrid models that can incorporate wider cross-market risk factors help
manage potential mispricing and hedge
effectiveness. The ability to scale computations is critical. Institutions looking to
put pricing and risk infrastructure in
a single framework require a big data
strategy and the ability to recalculate
entire portfolios.
In today’s economy, institutions are
very cost conscious and are looking at
innovative ways to manage costs. Many
are now looking at cloud as a distributed
infrastructure for the scale of calculations required to meet the requirements of the operations, while effectively
managing costs. The use of open-source
components is becoming standard in
waterstechnology.com/ird
Ian Blance,
Head of Business
Development for
Evaluated Pricing,
SIX Financial Information
+44 (0) 207 550 5430
six-group.com
many institutions. In looking at valuation providers, institutions should bring
in their IT departments to help assess
integration requirements and the use of
best-of-breed components. Lastly, many
institutions are using either proprietary
or vendor trading and risk systems, or
a combination of both. Institutions need
to assess the integration capabilities
of the vendors’ pricing, their APIs, and
existing integrations.
Blance: Coverage is a perennial problem.
Today, there is a greater need for objective valuations across a much broader
range of asset classes—including derivatives and structured products—which
creates a serious business problem for
users. Pricing vendors are under pressure to produce valuations for a larger
universe of instruments, many of which
are more complex and esoteric than the
most common fixed-income products.
April 2013 13
Virtual Roundtable
Transparency (in the sense of users
being able to completely understand
how a valuation was produced) remains
a key and growing requirement.
However, we are increasingly seeing
this aligned with the need for users
to be able to justify the use of a price
source to various external parties—
their clients, risk teams, auditors and
regulators. We call this combination of
transparency and justifiability “defensibility,” and have built our new evaluated
pricing service around this fundamental concept.
For portfolio managers, how much
of a factor is the credibility of pricing sources? How can firms and
providers address gaps in trust
concerning pricing?
White: Credibility of pricing sources
is a very high priority for portfolio
managers and asset owners in general.
“We are increasingly seeing
[the need for transparency]
aligned with the need for users
to be able to justify the use of a
price source to various external
parties—their clients, risk
teams, auditors and regulators”
Ian Blance, SIX Financial Information
14
April 2013
Likewise, it’s of paramount importance
to us. As the world’s largest custodian,
we are stewards of enormous amounts
of data, including pricing data. The
best way to close the trust gap is by
optimizing valuation practices and
price modeling techniques for greater
transparency. One indicator of the
shift that has occurred over the past
decade with respect to pricing is how
often we’re asked to provide multiple
valuations from different vendors to
clients. Portfolio managers today might
ask for information they wouldn’t have
requested 10 years ago. For instance,
they might want to see required variables such as yield curves in order to
calculate a price on a thinly traded or
illiquid issue. There’s much greater
focus today on value at risk, and that’s
driving a lot of the conversations related to the quality of valuations.
Hepsworth: Credibility of pricing
sources is paramount, and transparency is the bridge to building trust.
Gaps in trust between fund managers and price vendors may stem from
concerns over the quantity or quality of
a vendor’s market information. Trust is
also established by setting up an effective workflow for communicating and
monitoring challenges to a vendor’s
prices. In 2009, Interactive Data intro> continued on page 16
irdonline.com
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Reference Data, Buy-Side Technology,
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Building upon the success of the 2012
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opportunity to network with hundreds
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For more details on sponsoring or exhibiting
contact Jo Garvey
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Virtual Roundtable
duced the Evaluated
Pricing
Challenge
Portal, a web-based
application that offers
our clients a framework
for submitting, tracking
and analyzing challengKerry White,
es. We also offer an API
BNY Mellon
that allows clients to
integrate the Challenge
Portal into their internal systems to
help improve operational efficiency.
O’Hanlon: To address pricing gaps, buyside participants need to know when
trading in a bilateral margin situation
whether the margin calls are correct
or they are over-margined. They must
make sure that the margin cost in their
firm doesn’t actually overshadow the
benefit of having that trade on their
portfolio. If buy-side participants move
to a centralized counterparty, margining
happens much faster, sometimes from
weekly to intra-day. Many third-party
solutions charge based on the volume
and frequency of margin calls, thereby
increasing the cost of margining.
Blance: In the final analysis, valuation is a
trust business. If the valuation of a financial instrument cannot be trusted, then
the whole edifice of the financial system
is built on unsound foundations. This
was revealed most dramatically during
16
April 2013
the recent credit crisis, where liquidity in
many sectors collapsed because investors
could not trust the value of their holdings.
Addressing the gap in trust in valuation falls back to the previously
mentioned concept of defensibility.
If users can both understand exactly
how a valuation was produced and fully
justify the methodology, inputs and
assumption used in the process, then
a strong level of trust can be placed in
the robustness of the price. There are
a number of ways in which this trust
can be developed further. Complete
transparency is hugely important, as
is external review and validation of a
vendor’s methodology and process.
Do forms of pricing such as evaluated pricing have greater credibility
with users? Are other pricing and
valuation specialties with similar or
other attributes gaining traction?
White: We live in an era that continues to
challenge our information management
practices—evolving regulatory demands
and increased demands for transparency
continue to shape how we work with
our pricing vendors. For some investors,
evaluated prices do offer greater credibility, but they come at a premium.
With multiple pricing vendors operating in the marketplace and the regulatory mandate for greater transparency
in valuation oversight and governance,
irdonline.com
investors are demanding greater detail
from their service providers regarding
the pricing process and the underlying
data employed in the determination of
fair market values. This is particularly
true when traded prices are not readily
available. Adding to the complexity is
the scrutiny that is taking place regarding the use of derivatives by pension
funds. The pricing of derivatives and
other non-traditional investments,
combined with the absence of readily
available market quotations, is posing
challenges for sponsors and their auditors. This, coupled with the increased
pressure on plans themselves to adhere
to tightening corporate governance
standards, is making the landscape even
more complex.
Hepsworth: Our clients appreciate the
importance of independent, high-quality
evaluated prices. While methodologies
“Investors want greater detail
from service providers regarding
the pricing process and the
underlying data employed in
the determination of fair market
values, particularly when traded
prices are not available”
Kerry White, BNY Mellon
waterstechnology.com/ird
can vary, acquiring market information
from a wide array of sources and having
the people and tools to effectively and
efficiently analyze and incorporate the
data are critical to offering high-quality
valuations for thinly traded instruments.
This combination of technology, robust
models and a highly experienced and
professional staff of more than 400 fulltime professionals on our pricing and
reference operations team is what differentiates Interactive Data’s evaluated
pricing from competitors.
Blance: Our view is that a fully transparent and validated evaluated pricing
service fully meets user requirements for
a credible valuation source. However, it
appears that some users are still deeply
wedded to the concept of a “market
price”—either a trade or a quote from
a dealer. While it is true that in liquid,
normally functioning markets market
prices are perfectly valid, they begin to
succumb to some credibility issues when
these circumstances do not apply.
An appreciation of these issues and
the failings of many market prices, and
what options are available to address
them, is gradually beginning to emerge
in some of the more sophisticated users,
but this has some way to go. Regulation
is likely to continue to take user firms
down this path, but some will no doubt
be led kicking and screaming.
April 2013 17
Q&A
Pricing Decisions
Inside Reference Data speaks to Daniel
Johnson, vice president, valuation, Wells
Fargo Global Fund Services, about defining
data quality in prices and quotes, and
factors in choosing sources
Has data quality become a greater
part of considerations for pricing
and valuation operations?
Data quality is always quite important
to us. But the obvious question is how
to define good or bad quotes in data. It
depends on where you are standing and
what your perspective is.
You must have an opinion as an asset
manager. Which prices for a security do
you want, and which don’t you want?
You can’t just say you want the high
or low ones. And with the regulatory
changes that have come in, particularly the Alternative Investment Fund
Managers Directive, it will be more
important.
With concerns about transparency
of price sourcing, are broker quotes
reliable? Are they useful?
For asset managers, broker quotes
are useful in that you get a price and
can see where the price came from.
Traders know that those firms [that
supplied the price] trade that security
18
April 2013
Daniel Johnson
and therefore the price is reliable. The
downside is the quotes provided by
the broker often include a disclaimer
that the prices are indicative only and
should not be relied on for valuation or
any other purpose.
Where do you see innovation and
improvement happening among
providers now?
In price competition. I’m surprised it’s
taken this long to appear but I think
it definitely is appearing now. Many of
the large providers are offering similar
services with similar coverage.
Therefore, for high-volume dealers,
the bottom-line cost can make a difference to the end-user. This won’t make
up for poor data quality or coverage,
but if everyone is getting quotes from
similar places and coming back with
similar numbers and coverage, then the
only differentiator left is cost.
For more of Daniel Johnson’s thoughts,
please see “Interview With” in the April Inside
Reference Data.
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