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Archive for July, 2011

Rationality is Overrated

Tuesday, July 19th, 2011

When I was in school, I was the “class brain.”  (sigh, I had a hard time with it, but after I became a Christian, I won people over by offering homework help for free) I even have this glow-in-the-dark rubber brain that my senior class awarded me.

But it’s not worth that much.  There are many other character attributes desirable to society aside from being smart.  As a little kid, I was a guinea pig for many of the educational theories they tried to test on me, and I survived them.  Not sure what good they got out of it.

In my adulthood, I learned to appreciate the abilities of others who may be less smart, but they have gifts — empathy, mechanic, insightful into people, technical specialties… everyone has something to give, IF they will give.

Economists have a fixation on rationality, and this article is a partial expression of that.  My answer to the article is the people are limitedly rational.  That’s vague, and won’t fit into mathematical theories, but it is accurate.  It explains why people act rationally in some situations, and why they could be more rational in other situations, assuming that economists really know what is rational.  More goods is better is not an adequate explanation of rational.

A view like mine would make it very difficult for economists to create simple mathematical models of reality.  They would rather live in their fake world, where they can publish nonsense to peers, and keep their cushy jobs.

Get the US Government Out of Lending & Insurance Businesses

Tuesday, July 19th, 2011

I’ve done lots of things in my life in financial businesses.  It’s given me a chance to see a lot of different businesses from different angles.

One thing that surprised me as I learned, was how many places the US Government had lending and insurance programs.  Housing, Agriculture, Veterans, Shipping, Exports, Imports, and more.

But the worst of it was that most of it was non-economic.  I understand giving small subsidies, but not big ones.  Few programs tested the price-sensitivity of borrowers and insurance clients by raising rates until some said, “Ouch! I will do without this insurance.”  To me, not doing that is disrespectful to taxpayers, and promotes borrower dependence on the government, leading to too much debt/ cheap insurance.

Thus, I get annoyed by proposals to continue or expand government lending programs, particularly failures like Fannie Mae and Freddie Mac.  F&F created the conditions for an oversupply of housing.  My view is fold them into Ginnie Mae, and then send Ginnie Mae into runoff.  No more new loans.  Let the private banks fund new loans.  We don’t need more houses at present; past housing policy was a great big fail.  The cumulative losses of F&F prove it.

Let the FDIC raise its guarantee fee until some banks decide to do without it.  Once that starts to happen, drop it a little, and stay there.  If F&F continue to exist, let them raise their guarantee fees until lenders beging to seek other options.

I would much prefer the government exit such businesses, but I am in a minority I suspect.  At a minimum, have them behave like market driven firms, or at least like profit-seeking monopolists.

I write this because I don’t believe that borrowers or insureds deserve to be subsidized by our government.  Subsidizing businessmen has a bad smell.  If they can’t make it on their own, they don’t deserve to make it.

Silent as Night

Tuesday, July 19th, 2011

When I worked at a life insurer that was in the pension business, we would sometimes get asked to quote on business where termination of the existing plan would result in a surrender charge.  Now no plan sponsor would ever want to deliver a loss to participants — the effect on morale would be huge, so they would approach companies like ours and say something to the effect of, “If you pay our surrender charge off, we will invest with you.”

Not the happiest way to get business, but we reckoned that the fault was on the side of those that accepted the surrender charges in the first place.  We never did surrender charges on new business, but in order to get plan sponsors out of underperforming money managers, we would offer to pay off the surrender charge, at a price of a higher management fee plus a surrender charge.  We didn’t charge anything extra; we left our profit margin the same as with new clients.  We offered plan sponsors longer and shorter surrender charges, with correspondingly lower and higher annual fees.

As my friend Roy said, “We’re the good guys.  We’re out to save the world for 0.25% on assets plus postage and handling.”  But being “good guys” we helped hide the stupidities of plan sponsors, and to some degree, the cupidity of some mutual fund purveyors.

It also taught me a lesson.  When fees are deducted daily, no one notices.

You have read articles about how high mutual fund fees are, and you wonder why people buy them.  They buy them because they don’t look at the fees, and the fees get taken out quietly, night-by-night, imperceptibly.  They might also earn money from securities lending and soft dollar commission arrangements as well.  Their investors might reimburse some expenses also.

Now as for me, my business has just one source of revenue, my management fee as a percentage of assets.  I receive nothing else, and pay all expenses out of those fees.  It comes out once per quarter.  Savvy investors ask for direct billing, which I happily do, rather than deduction from the assets.

But it makes my cost to them very visible.  I am happy to live with that; I hope they are as well.

For those who use mutual funds, I suggest that you review the fees that you are paying. For those with 401(k) and similar plans, I suggest you look at the form 5500 documents behind your plan to see what you are implicitly paying.

Be aware.  In investments, charging through modest changes in the net asset value is the way most fees get siphoned off.  Big firms don’t like to talk about this, because it is their lifeblood.  You are your own best guardian, so review the fees of the firms that you entrust to invest your money.

US vs Moody’s, S&P and Fitch

Saturday, July 16th, 2011

The rating agencies are the whipping boys of the market.  Like princes who had a whipping boy to take the hit for their transgressions, so the rating agencies take the hit that should go to the regulators, which delegated their  credit-risk responsibility to the rating agencies.  That works out well for all, in one sense: the rating agencies make money, and the regulators escape blame.  What could be better?

But now we face another situation with the rating agencies, where they will finally downgrade the US Government from AAA.  Long overdue, particularly when one looks at the entitlement promises.

But people put up all manner of objections to the rating agencies doing what they should have done ten years ago.  Here is the big one:

The rating agencies never get it right

Not true.  On corporate credit, their ratings are highly predictive, and even yield insights into the movement of stock prices.  Now, if you are talking about securitized credit, you have to understand one thing: no one gets a debt market right until it has been through a failure cycle.  The rating agencies use what little data exists, usually from loans that are held on-balance-sheet, and apply them to loans that are originated and sold.  Doesn’t work that well, but who had better data, because it was a new practice?  Everyone failed on securitization, and only a few of us questioned it in advance.

With government credit, the rating agencies have been right for the most part.  Why?  For the most part, rating agencies are honest dealers when it comes to credit.  To be otherwise would damage their reputation.

Other Objections

Others talk about what the US or the EU could do to muzzle the rating agencies, because the downgrades complicate their actions.  I would say that the Rating Agencies are late if anything — the agencies don’t have much impact on their own.  The big impact is that not enough cash will flow to service debt and other demands on cash at the right time.

If the rating Agencies were muzzled, it would not change the cash flows one whit, except that there would be greater distrust from lenders, because the referees were forcibly silenced.

So what happens if the US gets downgraded?

Not much.  As I have said before, the ratings don’t mean much, except to regulators.  Yields shouldn’t move much, and if there is a sovereign ceiling at Aa2/AA, that will be the benchmark for all US yields, and corporate/municipal/securitized yields won’t shift much, because the economic reality hasn’t changed much.

What will change are investment guidelines that require Aaa/AAA investments.  They will reflect the lower top category, and not force investors to buy foreign AAA dollar-denominated bonds.

What happens if the debt ceiling isn’t raised?

Not sure.  There are lots of things that can happen:

  • Prioritizing payments
  • Not paying principal or interest on bonds (not likely)
  • Issuing scrip (haven’t heard it yet, but who can tell, states have done it)
  • Martial law is declared, and the Constitution is null and void (again, not likely)

A genuine full default by the US Government would have many ugly consequences, and should be avoided.  Prioritizing payments would be ugly, but could force our government to do the hard questioning that it has avoided for a long time — what are the priorities of our government?  What would we spend money on if we were deciding on priorities today, rather than the dead ideas of the past?

What, Me Worry?

I have concern over a lot of things, but the debt ceiling does not make it for me.  The bigger entitlement issues have been ignored for 40 years, and I have covered them for 20 years.  This is not the end, but the beginning of debates over where the resources of the US go, and how much is extracted from the populace.  The real test will come when Medicare is reduced, and how well the voters accept that.

Book Review: The StockTwits Edge

Saturday, July 16th, 2011

This is an unusual book.  Like most books that involve the internet, the pace of change is so rapid that it will probably not be valuable two years from now.  But in the short run there can be benefit.

The book is 46 essays from people who are engaged to some degree in using StockTwits, a popular internet site where traders and investors exchange thoughts about investments.  The internet encourages fast exchanges of data — after all, it is called StockTwits because of Twitter, not because they are fools (Twits).  There’s another investing site for Fools, Motley as it is, and it has its own charm.

But speed in gathering information on investing is more suited to trading than investing, and so it should be no surprise that the book is 90% geared to trading, and 10% to fundamental investing.

Thus the book has the most value for those who want to learn to trade better — there are 42 traders giving their opinions on how to trade.  But the average chapter is only 8 pages long, so all you get of any trader is a taste of what they do.

My advice would be to read the book, scan for the traders/investors that fit you personality well, and talk with them at their websites to get a fuller picture of what they do.  (My favorites were Eddy Elfenbein and Todd Sullivan.)

Quibbles

Personally, I would have done a book with fewer participants and longer chapters.  I also would have included more about how StockTwits itself improves investing.  Finally, I would have had that great internet finance curator, Tadas Viskanta write the last chapter.  It would have really added to the book.

Who would benefit from this book:

Traders looking for a taste of the strategies of others would benefit from this book.  Fundamental investors will find this to be thin gruel.

If you want to, you can buy it here: The StockTwits Edge: 40 Actionable Trade Set-Ups from Real Market Pros (Wiley Trading).

Full disclosure: The publisher asked me if I wanted it.

If you enter Amazon through my site, and you buy anything, I get a small commission.  This is my main source of blog revenue.  I prefer this to a “tip jar” because I want you to get something you want, rather than merely giving me a tip.  Book reviews take time, particularly with the reading, which most book reviewers don’t do in full, and I typically do. (When I don’t, I mention that I scanned the book.  Also, I never use the data that the PR flacks send out.)

Most people buying at Amazon do not enter via a referring website.  Thus Amazon builds an extra 1-3% into the prices to all buyers to compensate for the commissions given to the minority that come through referring sites.  Whether you buy at Amazon directly or enter via my site, your prices don’t change.

 

Don’t Play Near the Cliff

Thursday, July 14th, 2011

As a nation or a corporation moves from being a safe credit [borrower] to being an unsafe credit, often the transition is more rapid than one would expect.  Success has many fathers, and people are reluctant to change their views rapidly.  But once the views change, it is very difficult to change them back.

Part of that is due to the construction of the markets.  Relatively little money is “go anywhere” in bonds.  There is significant segmentation.  Bond investors divide into safe and aggressive, with not a lot that can bridge the gap.  The same applies to banks, which have limits on what they can lend to corporate non-investment grade clients.

This problem gets worse with companies, quasi-governments and governments that are “confidence names.”  I never, ever, fully bought into the ratings agencies views on financial guarantors, mortgage guarantors, and the GSEs.  There was always a significant amount of hand-waving, suggesting that:

  • Disaster scenarios were impossible, and
  • There would be support from the government (for the GSEs).
  • Governments can easily raise taxes to pay off bonds.

The group of credits most in question today are governments.  There are a number of stages in-between health and default.

  1. Government has little debt, budget is largely in balance.
  2. Government has moderate debt, budget is slightly inbalanced, but not so much that the interest rate on the debt exceeds the GDP growth rate.
  3. Government has significant debt, budget is in significant deficit, but the interest rate on the debt does not exceed the GDP growth rate, because creditors expect the situation to be transitory.
  4. Government has significant debt, budget is in significant deficit, but the interest rate on the debt exceeds the GDP growth rate, because creditors expect the situation to be permanent.
  5. Default. Forced Exchange. Etc.

Note that the difference between phases 3 and 4 are only in the way a government gets viewed by creditors.  That shift often happens rapidly, and the ratings agencies tend to be lagging indicators.

My counsel to borrowers would be simple: don’t play near the cliff.  Once you move into phase 4, it is very difficult to move back into phase 3.

Now with governments that can print their own currency they might say that they have more flexibility. They do, economically.  They don’t, politically.  There are major constituencies against inflation that would rather force a government into default than tolerate inflation that disproportionately hurts them.

So be wary when lending to entities depending on lender confidence.  That confidence can disappear in an instant, leaving you to hold a depreciated loan with uncertainty as to whether it will be paid off.

 

Reparations

Thursday, July 14th, 2011

The current book I am reading is Lords of Finance: The Bankers Who Broke the World.  Great book, long book, and I am one-third through it.

Britain and France borrowed a lot of money from the US to fight WWI.  After the Allies won the war, they pushed the costs of the war onto the Germans, partly in an effort to defray their costs of repaying the US.  The Germans could not bear such a load, and it  led to renegotiations, hyperinflation, etc.

Germany needs to be thankful that eventually the victors gave up pressing their demands, and that after WWII, the Americans not only did not ask for Reparations, but sent the Marshall Plan to rebuild Europe.  Germany is not as merciful as America in the 1940-50s.

But Germany is not as generous toward the Euro-fringe as the the US was toward Germany.  Much as Greece and others cheated to get into the Eurozone, it is not as if intelligent people could not see the dodge.  The Eurozone was/is a political construct to unify Europe.

Now Germany and the rest of the core extends loans to the fringe at rates that they will not be able to pay back.  Now admittedly Greece has problems, but those are Greece’s problems.  If they are not willing to deal with abnormally early retirement, or tax evasion, that is their problem, and they should feel the effects of their idiocy.

But after reading the history of post-WWI Europe, I am less optimistic that imbalances can be easily addressed.  Better that Germany should support its banks, and let the fringe fail.  It would be the best solution for all involved, after all, currency unions have never worked without political union.

The analogy is not exact, but there is a lot of trouble trying to get other nations to go along when it means making capital outflows.  No one in the euro-fringe is ready to send any significant amount of capital abroad.

Personally, I expect this to end with a smaller Eurozone, minus the fringe.  Then the new Eurozone can fight over smaller issues.

My view is that the Eurozone will implode before China or the US implodes.  Personally, I think the US will be the last of the bunch — that’s  just the way of the US, DV.

My main point is to make clear that the instabilities of Europe need not affect the US much.  I invest money looking at the world as a whole, attempting to make money for clients.

 

The Costs of Illiquidity

Wednesday, July 13th, 2011

Liquidity is underrated.  What’s that, you say?  You are earning nothing on your slack cash balances?

Well, welcome to the club.  I am earning nothing there as well.  To earn money on short duration assets in this environment means taking risks, like Pimco does with its ETF with the ticker MINT.

Now, many will offer yield in an environment like this, but at a cost — a long surrender charge.  The long surrender charge hides the transfer of future yield to the present.

I am talking  about more than annuities here.  There are other illiquid investments being proffered today that offer a high “yield,” notably fixed payment streams from insurance companies that are life-contingent.

This is the deal:  There are some annuitants who would rather have a lump sum than a payment stream.  Some firms will buy the payment stream at a price attractive to them.  Then they try to sell the payment stream to an investor at a higher price, thus eliminating their risks on the annuitant prematurely dying.  But how good as an investor would you be at evaluating the risks?

  • You do realize that you aren’t buying a bond here — at the end you are not getting your principal back.  So what’s the yield? — it isn’t the annual payment divided by the purchase price because part of each payment is an uncertain partial return of principal.  Do you have your own actuarial consultant to calculate the yield, or are you blindly trusting the seller?
  • So you bought out the annuity of another person.  How certain are you that he will live a long time?  Why are you smarter than the seller regarding  his own life?
  • Unlike an annuity on your own life, the payment stream may end before or after you die — a classic asset/liability mismatch.
  • Is there any possibility that you will not get paid?  Is your contract illegal?  Have you retained your own counsel in the matter, or are you trusting the seller?
  • Do the IRS immediate annuity tax rules apply in this situation?
  • If you need cash, you will have a hard time selling this — one of the few potential buyers is the friendly guy that sold it to you.  The price spread between selling and buying is huge, and not in your favor.
  • You do realize that unlike an annuity on your own life, this is not judgment-proof.

There are all manner of illiquid investments offering yield, but almost all of them lock the investor up for a time.  Think of them as quirky Certificates of Deposit, minus the FDIC.  Particularly egregious are EIAs with long and high surrender charges.  (The agents are paid a lot to sell those.  Never trust an insurance agent who is receiving a large commission to sell you an annuity.  Note: if they won’t disclose the commission, know that it is roughly the size of the initial surrender charge.)

The Cost

Illiquidity means a loss of flexibility.  If your money is tied up during a fall in the market, you will not be able to take advantage of what could be a 30-50% return over one or two years when the market bounces back.  That is a lot to give up for a little bit of yield.  Personally, I prefer flexibility.

The costs of illiquidity are quiet.  The extra yield seems free until there is a need for ready cash, whether to spend or to take advantage of investment bargains.  Personally, I’ll take the loss of income, and keep the flexibility.

Also, avoid unusual investments that are hard to evaluate unless you have expertise greater than that of the seller.  Don’t buy what someone wants to sell you; buy what you have researched and want to buy.

PS — this is another reason why I encourage people avoid “sales loads” in investing.  Mentally, it ties your hands, because you want to recoup the load, or not incur the surrender fee.

 

Full disclosure: I have one client that owns MINT in his portfolio with me as a cash substitute.

Enduring Ponzi

Saturday, July 2nd, 2011

Why did Madoff’s Ponzi scheme last so long?

  • He didn’t take that much from it.  If the gross exposure was $60 billion, he took only 1/2% of it — $300 million.
  • The growth rate was high enough to attract investors but slow enough to not exhaust cash rapidly.
  • The SEC was clueless, with little expertise in quantitative investing, and little basic auditing knowledge where one traces every transaction back to the source, which would have revealed Madoff in an instant.  There were no assets in the accounts.
  • He had a reputable business that produced significant profits, and was viewed by many as an industry leader.  Many Europeans, among others, thought he was front-running, and Madoff implicitly encouraged that idea while explicitly denying it.  The idea of “front-running” was a honey pot to distract regulators from the idea that a Ponzi scheme was going on.
  • The marketing club.  You are the lucky one who is invited to partake of the gravy train.  Don’t question, just enjoy, and refer friends, maybe we will consider them.
  • Feeder funds that were looking for looking for a high-ish return and a low standard deviation found Madoff irresistible.
  • “Pus luck.”  There were many times where the scheme almost died, but new cash flows bailed them out.  The term, “pus luck” was unique to my block where I grew up in Brookfield, Wisconsin, and described a situation of undeserved luck.  A brother of my friend, and a friend of my brother always seemed to get the lucky break at unusual moments.  We called it “pus luck,” perhaps in an effort to denigrate his skill in unlikely situations.
  • Madoff did not encourage a marketing frenzy.  He tried to keep it low-key.  That kept it below the radar, and allowed it to be marketed to a wide number of people who would not fall for a hard sale.

And so it was for Madoff, skating through unlikely situations where others would have easily died, until it got too big, as all Ponzis do.

We know when it ended, but have no idea on when it started, ’60s, ’70s, ’80s, ’90s…  We really don’t know.   Madoff has revealed a lot, but he has never given a date earlier than 1992.  His associate, DiPascali, suggested it may have started in the late ’80s.  There is some evidence that it may have gone all the way back to the ’60s.

I find DiPascali’s words to be more reasonable than Madoff’s.  The late ’80s were more desperate than the early ’90s.  If you could survive ’87 and ’89, you could likely survive ’92.

Recoveries?

When the Ponzi was revealed, few thought there would be any significant recoveries. But now, net losers from the Madoff Ponzi may get back over 50% of their money.  Why?

  • The Picower family gave in, and released their profits from the Madoff scheme.
  • Many large financial companies played small roles in the scheme, and they will all probably pay something to make the lawsuits go away.
  • Some net losers were involved in money laundering and are unlikely to pop their heads above water to make a claim on their ill-gotten funds.  More for the rest.

In one sense, the slowness of the Madoff Ponzi allowed for a less wasteful class of investors to be bilked.  Including Madoff, these were not the sorts of people that were big spenders as a fraction of their income.  Many investors were buy and hold with Bernie, and indeed, he encouraged that.

So the endgame may not be as bad as expected.  Many will get a large portion of their net investment back.  There will still be regrets, but they will be much reduced.  Good for them.

Book Review: The Wizard of Lies

Saturday, July 2nd, 2011

This is the best book that I have read on the Madoff scandal so far.  Why is it great?

  • It is well written.
  • There are few if any factual errors in the text.
  • She talked with a wide number of people to try to get the full story.
  • It’s neutral.  it doesn’t takes positions on a wide number of unanswered questions, and treats what Madoff says with skepticism.
  • It takes you through the previously unwritten history of the scam, where the only real doubt is when the scam started — did it start in the early ’90s, late ’80s, or in the ’60s?  We still don’t know.

Now, I have reviewed the books by Markopolous, and the Madoff “victims.” Each tries to make themselves look good.  The author of this book has no dog in the fight, and nothing to prove.

According to this book, Markopolous discredited himself via crude behavior, fear of retaliation, and inability for the SEC to understand simple quantitative investing concepts.  The “victims” did not exercise common prudence.  The biggest red flag over any investment business is no independent custodian, and that was glaring with Madoff.

Yes, they were victims, but they were people who should have known better.  To call oneself a victim here is to call oneself stupid.

There will be another article after this one to explain why the Madoff Ponzi lasted so long, and why the recoveries ended up so much higher than anticipated.

Book Structure

The book starts with the blow-up, and then reverts to telling the life story of Madoff, progressing to the eventual demise, but with many blow-ups averted in the interim.  After that, one-third of the book deals with the aftermath, with the suicides, estrangement, and aggressive lawyers that recover far more than was originally expected.

It’s quite a tale.  I learned a bunch here, and recommend the book to you.

Quibbles

None.

Who would benefit from this book:

If you want to understand how Madoff did it, this is the book to read.  If you want to get a feel for how to avoid con men, this book will also be useful.  Give it to your overly credulous brother-in-law.

If you want to, you can buy it here: The Wizard of Lies: Bernie Madoff and the Death of Trust.

Full disclosure: The publisher asked me if I wanted it.

If you enter Amazon through my site, and you buy anything, I get a small commission.  This is my main source of blog revenue.  I prefer this to a “tip jar” because I want you to get something you want, rather than merely giving me a tip.  Book reviews take time, particularly with the reading, which most book reviewers don’t do in full, and I typically do. (When I don’t, I mention that I scanned the book.  Also, I never use the data that the PR flacks send out.)

Most people buying at Amazon do not enter via a referring website.  Thus Amazon builds an extra 1-3% into the prices to all buyers to compensate for the commissions given to the minority that come through referring sites.  Whether you buy at Amazon directly or enter via my site, your prices don’t change.

Quibbles

The main difficulty is this: just because A follows a similar power law to B, does not mean that A & B have something in common.  There are often spurious correlations.

Who would benefit from this book:

Most serious investors and academics could benefit from the book.  It will challenge your preconceptions.  That doesn’t mean that everything Mandelbrot writes is correct, but most of his criticisms of MPT are correct.  The question becomes what to replace MPT with?

If you want to, you can buy it here: The Misbehavior of Markets: A Fractal View of Financial Turbulence.

Full disclosure: I bought the book with my own money.

If you enter Amazon through my site, and you buy anything, I get a small commission.  This is my main source of blog revenue.  I prefer this to a “tip jar” because I want you to get something you want, rather than merely giving me a tip.  Book reviews take time, particularly with the reading, which most book reviewers don’t do in full, and I typically do. (When I don’t, I mention that I scanned the book.  Also, I never use the data that the PR flacks send out.)

Most people buying at Amazon do not enter via a referring website.  Thus Amazon builds an extra 1-3% into the prices to all buyers to compensate for the commissions given to the minority that come through referring sites.  Whether you buy at Amazon directly or enter via my site, your prices don’t change.

Disclaimer


David Merkel is an investment professional, and like every investment professional, he makes mistakes. David encourages you to do your own independent "due diligence" on any idea that he talks about, because he could be wrong. Nothing written here, at RealMoney, Wall Street All-Stars, or anywhere else David may write is an invitation to buy or sell any particular security; at most, David is handing out educated guesses as to what the markets may do. David is fond of saying, "The markets always find a new way to make a fool out of you," and so he encourages caution in investing. Risk control wins the game in the long run, not bold moves. Even the best strategies of the past fail, sometimes spectacularly, when you least expect it. David is not immune to that, so please understand that any past success of his will be probably be followed by failures.


Also, though David runs Aleph Investments, LLC, this blog is not a part of that business. This blog exists to educate investors, and give something back. It is not intended as advertisement for Aleph Investments; David is not soliciting business through it. When David, or a client of David's has an interest in a security mentioned, full disclosure will be given, as has been past practice for all that David does on the web. Disclosure is the breakfast of champions.


Additionally, David may occasionally write about accounting, actuarial, insurance, and tax topics, but nothing written here, at RealMoney, or anywhere else is meant to be formal "advice" in those areas. Consult a reputable professional in those areas to get personal, tailored advice that meets the specialized needs that David can have no knowledge of.

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