Hern Investments provides monthly emerging market research to Baker Brokerage in exchange for prospective client referrals and European equity research from Baker. Clients and prospects of Hern are not made aware of the agreement, but clients unanimously rave about the high quality of the research provided by Baker. As a result of the research, many clients with non- discretionary accounts have earned substantial returns on their portfolios. Managers at Hem have also used the research to earn outstanding returns for the firm's discretionary accounts. Hern has most likely:

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