Exhibit 99.1

                    [LETTERHEAD OF W.P. STEWART & CO., LTD.]

2 August, 2007
Hamilton, Bermuda

Contact: Fred M. Ryan
telephone: 441-295-8585

                W.P. Stewart & Co., Ltd. Announces Second Quarter
                      and Six months 2007 Financial Results

Provides Update on Business Reorganization and Turnaround Initiatives

o     Second quarter GAAP loss of $0.39 per share (diluted) after non-recurring,
      non-cash  charge of $18.0  million,  or $0.39  per  share,  diluted;  GAAP
      earnings of $0.21 per share (diluted) in second quarter, 2006

o     Six months GAAP loss of $0.43 per share (diluted);  GAAP earnings of $0.49
      per share (diluted) for the six months ended 30 June 2006

o     Cash earnings of $0.11 per share  (diluted) for the second  quarter ($0.29
      per share,  diluted, in second quarter 2006) and $0.26 per share (diluted)
      for the six months ended 30 June 2007 ($0.60 per share,  diluted,  for the
      six months ended 30 June 2006) - see GAAP reconciliation statement below

      W.P.  Stewart & Co., Ltd. today  reported a net loss of $17.8 million,  or
$0.39 per share  (diluted)  and $0.39 per share  (basic) for the second  quarter
ended 30 June 2007. This loss reflects a second quarter non-recurring,  non-cash
charge of approximately $18.0 million, or $0.39 per share,  diluted,  related to
an impairment  of  intangible  assets.  This  impairment  reflects a decrease in
assets under management,  the fees from which were supporting  intangible assets
per the Financial  Accounting  Standards  Board (SFAS No. 142).  Excluding  this
non-recurring,  non-cash  charge,  second  quarter 2007 net income was $173,000,
less than one cent per  share.  These  results  compare  with net  income in the
second quarter of the prior year of $9.6 million,  or $0.21 per share  (diluted)
and $0.21 per share (basic).



      Cash  earnings  for the quarter  ended 30 June 2007 were $5.0 million (net
loss of $17.8 million  adjusted to include $22.8 million  representing  non-cash
income  and  expenses  consisting  of  unrealized  gains  and  losses,  non-cash
compensation,  depreciation,  amortization and other non-cash charges, including
the  non-recurring  impairment  charges on a tax-effected  basis),  or $0.11 per
share (diluted). In the same quarter of the prior year, cash earnings were $13.3
million (net income of $9.6 million  adjusted for the  inclusion of $3.7 million
representing expenses of non-cash compensation,  depreciation,  amortization and
other non-cash charges on a tax-effected basis), or $0.29 per share (diluted).

      Assets under  management  (AUM) at  quarter-end  were  approximately  $5.3
billion, compared to approximately $6.4 billion at the end of the prior quarter,
a decrease of  approximately  17.2% and a decrease of  approximately  36.9% from
$8.4 billion at 30 June 2006.

      For the  second  quarter  of 2007  there  were  46,060,247  common  shares
outstanding on a weighted  average  diluted basis compared to 45,915,096  common
shares  outstanding for the second quarter of 2006 on the same weighted  average
diluted basis.

      Management Review & Comment

      In announcing the results, William P. Stewart,  Chairman & Chief Executive
Officer,  said  "Overall,  while our  financial  results in the  second  quarter
reflect the  disruptions  of the past and the  preference of investors for other
strategies than US quality growth companies,  looking forward we believe we have
begun to see a change in investor mood coupled with a  strengthening  of our own
business and investment performance."

      The Company continues on the  reorganization and turnaround which began in
February of this year. The following highlights are noted:

      1.    Strengthening  and widening the employee talent pool is a key factor
            in the Company's turnaround efforts. As previously announced,  James
            D. Awad recently  joined the firm as Chairman of W.P.  Stewart Asset
            Management (NA), Inc. Also,  during the second quarter,  the Company
            added another  experienced  professional  to the New York investment
            team, one senior professional to our London based research group and
            one senior  client  service  professional  in New York.  The Company
            expects  to add  more  senior  people  to  our  U.S  investment  and
            corporate development areas over the next few weeks.

      2.    A review of the Company's  advisory  fees and brokerage  commissions
            has been completed.  A range of fixed and  performance  oriented fee
            choices is being  offered to  clients.  In  addition  to the changes
            announced last year, an advisory fee option  combining a lower fixed
            fee  with  a  performance   fee  has  been  introduced  for  account
            relationships  greater than $10 million.  Brokerage  commissions for
            account relationships totaling $10 million are being eliminated.  We
            also  now  offer a  fixed  fee  alternative  for  all  standard  fee
            relationships under that limit.

      3.    As part of an ongoing initiative to enhance  operational  efficiency
            and improve our cost  structure,  a thorough  review of expenses was
            completed  during  the  second  quarter.   The  Company's  corporate
            aircraft was sold last month for $18.8 million.  As the aircraft was
            fully  depreciated,  the  sale  is a  taxable  event.  Additionally,
            certain other expenses have been  identified for reduction and there
            has been a further reduction in employee count.


                                                                               2


            Accordingly,  there will be additional  one-time  charges related to
            employee terminations in the third quarter of 2007.

      4.    During the second quarter, the Company streamlined the framework for
            offering  the  W.P.   Stewart  global  and   international   (ex-US)
            investment  services  to  clients.   The  demand  for  international
            exposure  among the  Company's  clients is strong.  A large group of
            clients, related to a third party solicitor asked us to include some
            high  quality   international   companies   in  their   existing  US
            portfolios.  This  conversion is expected to be completed by the end
            of August.

      5.    At a recent meeting the Company's  Board of Directors  confirmed the
            policy that dividend  declarations  include a  consideration  of the
            Company's cash earnings as well as future  requirements for building
            out our global franchise.

      Six Month Results

      For the six months ended 30 June 2007,  the net loss was $19.6  million or
$0.43 per share  (diluted),  and $0.43 per share  (basic),  on revenues of $48.1
million.  This includes the  non-recurring  charges of approximately $18 million
noted above and  approximately  $5.8 million relating to agreements with certain
employees,  reached in the first  quarter  of 2007,  whose  employment  with the
Company terminated in that quarter. As noted, the second quarter  non-recurring,
non-cash  charge of  approximately  $18.0  million or $0.39 per share  (diluted)
related to an  impairment  of  intangible  assets.  This  impairment  reflects a
decrease  in assets  under  management,  the fees  from  which  were  supporting
intangible assets per the Financial  Accounting  Standards Board (SFAS No. 142).
Net income for the six months ended 30 June 2006 was $22.3  million or $0.49 per
share (diluted) and $0.49 per share (basic), on revenues of $74.8 million.

      Cash  earnings  for the six months  ended 30 June 2007 were $11.9  million
(net loss of $19.7  million  adjusted  to include  $31.6  million,  representing
non-cash income and expenses consisting of unrealized gains and losses, non-cash
compensation,  depreciation,  amortization and other non-cash charges, including
the  non-recurring  impairment  charges on a tax-effected  basis),  or $0.26 per
share (diluted).  In the same period of the prior year, cash earnings were $27.7
million (net income of $22.3 million  adjusted for the inclusion of $5.4 million
representing expenses of non-cash compensation,  depreciation,  amortization and
other non-cash charges on a tax-effected basis), or $0.60 per share (diluted).

      For the six months ended 30 June 2007, there were 46,023,754 common shares
outstanding on a weighted  average  diluted basis compared to 45,928,110  common
shares  outstanding  for the same  period in 2006 on the same  weighted  average
diluted basis.

      Performance

      Performance  in the W.P.  Stewart & Co., Ltd. U.S.  Equity  Composite (the
"Composite")  for the  second  quarter of 2007 was  +2.8%,  pre-fee,  and +2.5%,
post-fee. This compares to +6.3% for the S&P 500.


                                                                               3


      For the six months ended 30 June 2007,  performance  in the  Composite was
+2.1%, pre-fee, and +1.5%, post-fee. This compares to +7.0% for the S&P 500.

      For the  twelve  month  period  ending 30 June  2007,  performance  in the
Composite was +14.1%,  pre-fee, and 13.0%, post-fee.  This compares to 20.6% for
the S&P 500.

      Performance in the W.P. Stewart International portfolio (ex United States)
for the second quarter of 2007 was 6.0%, pre-fee, and 5.9%,  post-fee,  compared
to 6.4% for the MSCI EAFE Index.  Performance in the Global  portfolio was 5.5%,
pre-fee, and 5.3%, post-fee,  compared to 6.5% the MSCI World Index. For the six
months  ended  30 June  2007,  performance  in the  W.P.  Stewart  International
portfolio was 8.3%, pre-fee, and 8.0%, post-fee,  compared to 10.7% for the MSCI
EAFE Index. In the Global portfolio, performance for the six moths ended 30 June
2007 was 5.4%, pre-fee, and 5.0%, post-fee,  compared to 9.2% for the MSCI World
Index.

      Monthly Performance Reporting

      Beginning  with  July  2007,  the  Company  will  be  releasing  composite
portfolio investment returns on a monthly basis. These returns will be posted on
our website at www.wpstewart.com.

      Preliminary  indications  are that  performance  in July 2007 for the U.S.
Equity Composite was -1.2%,  pre-fee,  and -1.3%,  post-fee.  This compares with
- -3.2% for the S&P 500. The year-to-date  performance for the Composite, as of 31
July 2007 was 0.9%, pre-fee, and 0.2%, post-fee,  compared with 3.6% for the S&P
500.  For the twelve  months  ended 31 July 2007,  the  Composite  was up 17.5%,
pre-fee, and 16.3%, post-fee, compared with 16.1% for the S&P 500 Index.

      The Company's international performance remains strong. Performance in the
International  portfolios on a  year-to-date  basis as of 31 July 2007 was 9.9%,
pre-fee, and 9.6%,  post-fee,  compared to 9.1% for the MSCI EAFE Index. For the
Global portfolios performance was 5.5%, pre-fee and 5.0%, post-fee, year-to-date
as of 31 July 2007, compared to 6.7% for the MSCI World Index.

      The Stewart Asia Fund,  managed by our affiliate,  Bowen Asia and which we
will  be  including  in  our  monthly   reporting,   posted  returns  of  16.9%,
year-to-date  as of 31 July 2007,  compared to 12.9% for its benchmark,  the Dow
Jones Asia Pac.

      Assets Under Management

      Assets  under  management  (AUM) for the  quarter  ended 30 June 2007 were
approximately  $5.3 billion,  compared with  approximately  $6.4 billion for the
quarter  ended 31 March 2007 and $8.4 billion  reported at the quarter  ended 30
June 2006.

      Total net  flows of AUM for the  quarter  ended 30 June 2007 were  -$1,156
million,  compared  with  -$510  million in the  comparable  quarter of 2006 and
- -$1,663 million in the first quarter of 2007.

      Total net flows of AUM for the six months ended 30 June 2007 and 2006 were
- -$2,819 million and -$747 million, respectively.


                                                                               4


      In the second  quarter of 2007,  net cash flows of existing  accounts were
approximately  -$251 million compared with net cash flows of approximately -$207
million in the second quarter of 2006.  Net cash flows of existing  accounts for
the six months ended 30 June 2007 were -$490  million  compared to -$238 million
for the six months ended 30 June 2006.

      Net new flows (net contributions to our publicly-available funds and flows
from new accounts minus closed  accounts) were  approximately  -$905 million for
the quarter compared to approximately  -$303 million for the same quarter of the
prior year. Net new flows were  approximately  -$2,329 million and approximately
- -$509 million for the six months ended 30 June 2007 and 2006, respectively.

      Net flows in July 2007 were negative approximately $190 million.

      Look-Through Earning Power

      W.P. Stewart & Co., Ltd. concentrates its investments in large,  generally
less cyclical, growing businesses. Throughout most of the Company's history, the
growth in earning power behind clients' portfolios has ranged from approximately
11% to 22%, annually.

      Currently the "look-through" earnings power behind our clients' portfolios
remains solidly positive with portfolio  earnings per share growth on a trailing
four quarter  basis as at 30 June 2007 expected to have advanced at the high end
of the historical range. The Company's  research analysts expect  "look-through"
portfolio earnings growth to be within the 12-15% range over the next few years,
about twice the growth expected for the S&P 500 Index earning power.

      Revenues and Profitability

      Revenues were $22.2  million for the quarter ended 30 June 2007,  compared
to $38.5 million for the same quarter 2006. Revenues for the six months ended 30
June 2007 and 2006 were $48.1 million and $74.8 million, respectively.

      The average gross  management fee was 1.06%,  annualized,  for the quarter
ended 30 June 2007 and 1.07%, annualized, for the six months ended 30 June 2007,
compared to 1.13% and 1.13%,  annualized,  for each of the comparable periods of
the prior year.

      Excluding performance fee based accounts, the average gross management fee
was 1.23%, annualized, for the quarter ended 30 June 2007 and 1.22%, annualized,
for the six months ended 30 June 2007, compared to 1.25%, and 1.26%, annualized,
for each of the comparable periods of the prior year.

      Total  operating  expenses for the second quarter 2007 increased  39.1% to
$38.7  million,  and include the non-cash,  non-recurring  impairment  charge of
approximately  $18 million,  from $27.8 million in the same quarter of the prior
year.  Total  operating  expenses  were $66.6  million,  including the non-cash,
non-recurring  charges,  and $49.1 million for the six months ended 30 June 2007
and 2006, respectively.


                                                                               5


      The increase in employee compensation and benefits  substantially reflects
non-cash   compensation  expense  related  to  the  Company's  restricted  share
issuances to employees of approximately $9.3 million for the six months ended 30
June 2007,  which includes $4.2 million  related to employees  whose  employment
terminated in February  2007. In the  comparable  period of 2006 these  non-cash
compensation expenses were $2.6 million.

      We expect non-cash compensation expense related to restricted share grants
to be at least $14.5 million for 2007 versus $7.9 in 2006.

      The  Company's  provision for taxes for the quarter ended 30 June 2007 was
$1.3 million  versus $1.1 million in the  comparable  quarter of the prior year,
and was $1.2  million  versus $3.4 million for the six months ended 30 June 2007
and 2006, respectively.

      Other Events

      The Company  paid a dividend of $0.15 per common share on 27 April 2007 to
shareholders of record as of 13 April 2007, and will pay a dividend of $0.15 per
common share on 3 August 2007 to shareholders of record as of 23 July 2007.

      Conference Call

      In  conjunction  with this second  quarter  2007  earnings  release,  W.P.
Stewart & Co., Ltd. will host a conference call on Thursday,  2 August 2007. The
conference call will commence promptly at 9:15am (EDT). Those who are interested
in participating in the teleconference  should dial  1-800-289-0544  (within the
United States) or +913-981-5533  (outside the United States).  The conference ID
number is 4704671.  To listen to the live broadcast of the  conference  over the
Internet,  simply  visit  our  website  at  www.wpstewart.com  and  click on the
Investor Relations tab for a link to the webcast.

      The  teleconference  will be available for replay from Thursday,  2 August
2007 at 12:00 noon (EDT) through  Friday,  3 August 2007 at 5:00 p.m.  (EDT). To
access the replay,  please  dial  1-888-203-1112  (within the United  States) or
+719-457-0820  (outside the United  States).  The pass code for  accessing  this
replay is 4704671.

      You will be able to  access a replay  of the  Internet  broadcast  through
Thursday,  9 August 2007, on the Company's website at  http://www.wpstewart.com.
The  Company  will  respond to  questions  submitted  by e-mail,  following  the
conference.

      W.P. Stewart & Co., Ltd. is an asset management  company that has provided
research-intensive  equity management  services to clients  throughout the world
since 1975. The Company is headquartered in Hamilton, Bermuda and has additional
operations or affiliates in the United States, Europe and Asia.


                                                                               6


      The Company's shares are listed for trading on the New York Stock Exchange
(NYSE: WPL) and on the Bermuda Stock Exchange (BSX: WPS).

      For  more   information,   please   visit   the   Company's   website   at
http://www.wpstewart.com, or call W.P. Stewart Investor Relations (Fred M. Ryan)
at  1-888-695-4092  (toll-free  within  the  United  States)  or +  441-295-8585
(outside the United States) or e-mail to IRINFO@wpstewart.com.

      Statements made in this release concerning our assumptions,  expectations,
beliefs,  intentions,  plans or strategies are forward-looking statements within
the  meaning of the  Private  Securities  Litigation  Reform  Act of 1995.  Such
statements  involve  risks and  uncertainties  that may cause actual  results to
differ  from those  expressed  or implied  in these  statements.  Such risks and
uncertainties include, without limitation,  the adverse effect from a decline or
volatility in the securities  markets,  a general  downturn in the economy,  the
effects of economic,  financial or political  events, a loss of client accounts,
inability of the Company to attract or retain qualified  personnel,  a challenge
to our U.S. tax status, competition from other companies,  changes in government
policy  or  regulation,  a  decline  in  the  Company's  products'  performance,
inability of the Company to implement its operating  strategy,  inability of the
Company  to  manage   unforeseen  costs  and  other  effects  related  to  legal
proceedings or investigations of governmental and self-regulatory organizations,
industry  capacity  and trends,  changes in demand for the  Company's  services,
changes in the Company's  business  strategy or development plans and contingent
liabilities.  The information in this release is as of the date of this release,
and will not be  updated  as a result of new  information  or  future  events or
developments.


                                                                               7


W.P. Stewart & Co., Ltd.
Unaudited Condensed Consolidated Statements of Operations



                                                                        For the Three Months Ended
                                                               -------------------------------------------
                                                               June 30, 2007  Mar. 31, 2007  June 30, 2006
                                                               -------------  -------------  -------------
                                                                                     
Revenue:
  Fees                                                          $ 16,019,572   $ 21,061,944   $ 25,788,508
  Commissions                                                      4,256,289      4,459,454     11,916,558
  Realized and unrealized gains/(losses) on investments (1)        1,300,243        (21,201)        79,255
  Interest and other (1)                                             580,435        440,328        753,017
                                                                ------------   ------------   ------------

                                                                  22,156,539     25,940,525     38,537,338
                                                                ------------   ------------   ------------

                                                                  22,156,539        419,127
Expenses:
  Employee compensation and benefits                               9,487,651     16,149,555     11,228,135
  Fees paid out                                                    1,846,777      1,781,660      1,949,680
  Performance fee charge                                                  --             --      2,625,642
  Commissions, clearance and trading                                 726,948        787,965      2,245,933
  Research and  administration                                     3,070,359      3,392,907      3,330,257
  Marketing                                                        1,280,031      1,564,158      1,488,922
  Depreciation and amortization                                    1,448,278      1,438,229      1,648,745
  Impairment of intangible asset                                  17,985,000             --             --
  Other operating                                                  2,860,020      2,737,124      3,318,203
                                                                ------------   ------------   ------------
                                                                  38,705,064     27,851,598     27,835,517
                                                                ------------   ------------   ------------

Income before taxes                                              (16,548,525)    (1,911,073)    10,701,821

Provision for taxes                                                1,263,722        (74,295)     1,053,940
                                                                ------------   ------------   ------------

Net income                                                      $(17,812,247)  $ (1,836,778)  $  9,647,881
                                                                ============   ============   ============

Earnings per share:

Basic earnings per share                                        $      (0.39)  $      (0.04)  $       0.21
                                                                ============   ============   ============

Diluted earnings per share                                      $      (0.39)  $      (0.04)  $       0.21
                                                                ============   ============   ============


                                                                       % Change From
                                                                ----------------------------
                                                                Mar. 31, 2007  June 30, 2006
                                                                -------------  -------------
                                                                              
Revenue:
  Fees                                                                -23.94%        -37.88%
  Commissions                                                          -4.56%        -64.28%
  Realized and unrealized gains/(losses) on investments (1)         -6232.93%       1540.58%
  Interest and other (1)                                               31.82%        -22.92%
                                                                 ------------   ------------

                                                                      -14.59%        -42.51%
                                                                 ------------   ------------

Expenses:
  Employee compensation and benefits                                  -41.25%        -15.50%
  Fees paid out                                                         3.65%         -5.28%
  Performance fee charge                                                  --             --
  Commissions, clearance and trading                                   -7.74%        -67.63%
  Research and  administration                                         -9.51%         -7.80%
  Marketing                                                           -18.16%        -14.03%
  Depreciation and amortization                                         0.70%        -12.16%
  Impairment of intangible asset                                          --             --
  Other operating                                                       4.49%        -13.81%
                                                                 ------------   ------------
                                                                       38.97%         39.05%
                                                                 ------------   ------------

Income before taxes                                                   765.93%       -254.63%

Provision for taxes                                                 -1800.95%         19.90%
                                                                 ------------   ------------

Net income                                                            869.76%       -284.62%
                                                                 ============   ============

Earnings per share:

Basic earnings per share                                              875.00%       -285.71%
                                                                 ============   ============

Diluted earnings per share                                            875.00%       -285.71%
                                                                 ============   ============


Note (1) : Prior  period  amounts  have been  revised  to  reflect  presentation
consistent with current period reporting.



W.P. Stewart & Co., Ltd.
Unaudited Condensed Consolidated Statements of Operations



                                                                           For the Six Months Ended June 30,
                                                                   -----------------------------------------------------
                                                                        2007                2006                 %
                                                                   -------------       -------------       -------------
                                                                                                        
Revenue:
  Fees                                                             $  37,081,516       $  52,975,816             -30.00%
  Commissions                                                          8,715,743          20,177,352             -56.80%
  Realized and unrealized gains/(losses) on investments (1)            1,279,042             121,007             957.00%
  Interest and other (1)                                               1,020,763           1,509,342             -32.37%
                                                                   -------------       -------------       -------------

                                                                      48,097,064          74,783,517             -35.68%
                                                                   -------------       -------------       -------------

Expenses:
  Employee compensation and benefits                                  25,637,206          18,966,972              35.17%
  Fees paid out                                                        3,628,437           4,124,588             -12.03%
  Performance fee charge                                                      --           2,625,642                 --
  Commissions, clearance and trading                                   1,514,913           3,888,012             -61.04%
  Research and  administration                                         6,463,266           6,959,801              -7.13%
  Marketing                                                            2,844,189           3,200,016             -11.12%
  Depreciation and amortization                                        2,886,507           3,224,539             -10.48%
  Impairment of intangible asset                                      17,985,000                  --                 --
  Other operating                                                      5,597,144           6,080,340              -7.95%
                                                                   -------------       -------------       -------------
                                                                      66,556,662          49,069,910              35.64%
                                                                   -------------       -------------       -------------

Income before taxes                                                  (18,459,598)         25,713,607            -171.79%

Provision for taxes                                                    1,189,427           3,401,615             -65.03%
                                                                   -------------       -------------       -------------

Net income                                                         $ (19,649,025)      $  22,311,992            -188.06%
                                                                   =============       =============       =============

Earnings per share:

Basic earnings per share                                           $       (0.43)      $        0.49            -187.76%
                                                                   =============       =============       =============

Diluted earnings per share                                         $       (0.43)      $        0.49            -187.76%
                                                                   =============       =============       =============


Note (1) : Prior  period  amounts  have been  revised  to  reflect  presentation
consistent with current period reporting.



W.P. Stewart & Co., Ltd.
Net Flows of Assets Under Management*



                                                             (in millions)
                                                             -------------

                                                        For the Three Months Ended                    For the Six Months Ended
                                            -------------------------------------------------     -------------------------------
                                            Jun. 30, 2007     Mar. 31, 2007     Jun. 30, 2006     Jun. 30, 2007     Jun. 30, 2006
                                            -------------     -------------     -------------     -------------     -------------
                                                                                                     
Existing Accounts:
  Contributions                             $          56     $          83     $         168     $         139     $         497
  Withdrawals                                        (307)             (322)             (375)             (629)             (735)
                                            -------------     -------------     -------------     -------------     -------------
Net Flows of Existing Accounts                       (251)             (239)             (207)             (490)             (238)
                                            -------------     -------------     -------------     -------------     -------------
Publicly Available Funds:
  Contributions                                        19                75                78                94               112
  Withdrawals                                        (190)             (119)              (93)             (309)             (162)
Direct Accounts Opened                                 28               115                27               143                84
Direct Accounts Closed                               (762)           (1,495)             (315)           (2,257)             (543)
                                            -------------     -------------     -------------     -------------     -------------
Net New Flows                                        (905)           (1,424)             (303)           (2,329)             (509)
                                            -------------     -------------     -------------     -------------     -------------

Net Flows of Assets Under Management        $      (1,156)    $      (1,663)    $        (510)    $      (2,819)    $        (747)
                                            =============     =============     =============     =============     =============


* The table above sets forth the total net flows of assets under  management for
the  three  months  ended  June 30,  2007,  March  31,  2007 and June 30,  2006,
respectively, and for the six months ended June 30, 2007 and 2006, respectively,
which include  changes in net flows of existing  accounts and net new flows (net
contributions to our publicly  available funds and flows from new accounts minus
closed accounts).  The table excludes total capital appreciation or depreciation
in assets under  management  with the  exception of the amount  attributable  to
withdrawals and closed accounts.