Exhibit 99.2

                    [Letterhead of W.P. Stewart & Co., Ltd.]

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

1 November 2007
Hamilton, Bermuda


                 W.P. Stewart & Co., Ltd. Reports Net Income For
 Third Quarter of $9.2 Million and a Net Loss of $10.4 Million for the First
                              Nine Months of 2007

  Diluted earnings per share of $0.20 and a loss of $0.23 for the third quarter
                       and first nine months, respectively

          Cash earnings per share for the third quarter and nine months
                      were $0.29 and $0.56, respectively.

      Third Quarter 2007 Summary

      W.P.  Stewart & Co., Ltd.  today  reported net income of $9.2 million,  or
$0.20 per share  (diluted)  and $0.20 per share  (basic),  for the third quarter
ended 30 September 2007. These results include a non-recurring  gain on the sale
of the Company's aircraft of $10.2 million,  post-tax,  as well as non-recurring
expenses of $2.0 million related to agreements  with employees whose  employment
with the Company terminated in the quarter. This compares with net income in the
third  quarter of 2006 of $3.5 million,  or $0.08 per share  (diluted) and $0.08
per share (basic).

      Cash earnings for the quarter  ended 30 September  2007 were $13.3 million
(net  income of $9.2  million  adjusted  to include  $4.1  million  representing
non-cash income and expenses consisting



of   unrealized   gains  and  losses,   non-cash   compensation,   depreciation,
amortization and other non-cash  charges on a tax effected basis),  or $0.29 per
share (diluted).  In the same quarter of the prior year, cash earnings were $7.5
million (net income of $3.5 million  adjusted for the  inclusion of $4.0 million
representing   non-cash   expenses   consisting   of   non-cash    compensation,
depreciation,  amortization and other non-cash charges on a tax-effected basis),
or $0.16 per share (diluted).

      Assets under  management  at 30  September  2007 were  approximately  $5.0
billion,  compared  to $5.3  billion  at the end of the prior  quarter  and $8.3
billion at 30 September 2006.

      For the  third  quarter  of  2007  there  were  46,242,070  common  shares
outstanding on a weighted  average  diluted basis compared to 45,794,313  common
shares  outstanding  for the third quarter of 2006 on the same weighted  average
diluted basis.

      Management Comment

      Commenting on the quarter, Bill Stewart, Chairman & CEO, said "This was an
important period for our company, as we continued to attract strong, experienced
people  into key asset  management,  marketing  and  client  service  positions,
furthered  the  integration  of our global  research  and  portfolio  management
activities,  offered a range of advisory fee options and substantially broadened
our product line. Our financial results,  while disappointing,  reflect the time
and effort needed to rebuild our franchise,  as we are now  approximately  eight
months into a projected one- to two-year turnaround program.  I've said from the
start, the critical  challenge is to successfully  rebuild and differentiate our
company for the long-term.  I'm pleased that our new investment  management team
is virtually in place, working hard at improving  investment  performance and we
have reduced operating expenses.

      "Nevertheless,  while  we  generated  positive  cash  flow,  this  was  an
unsatisfactory  quarter as our results  reflected the ongoing outflow of assets.
We continue to expect it will take time before the impact of the  management and
operating  changes  takes full  effect.  I remain  confident we are on the right
track."

      As  previously  announced,  on  1  October  2007  the  Company  introduced
additional  new advisory fee options for clients and brokerage  commissions  for
account  relationships at $10 million and above were  eliminated.  These changes
are in  addition  to those that were  introduced  in the third  quarter of 2006.
Overall,  the restructuring of fees and commissions enhances our competitiveness
in the global wealth management market.


                                                                               2


      Also, as announced last week, to ensure the Company has the cash resources
necessary to continue  building out its global  franchise,  including  exploring
possible strategic opportunities,  the Board of Directors decided to suspend the
regular quarterly dividend payment to common shareholders.

      Investment  performance in the third quarter was  significantly  better in
the U.S.  portfolios  despite  the  turmoil in the  financial  markets  although
October was not as good and U.S. portfolio returns remain  disappointing for the
year to date.  Performance in the European and Asian  portfolios has been strong
and this strength has supported the International (EAFE) portfolio.

      Based on  performance  through the end of the third  quarter of 2007,  the
Company  may be  entitled  to  receive  performance  fees this year on a limited
number of its  accounts,  including on W.P.  Stewart  Holdings,  our mutual fund
listed on  Euronext  Amsterdam.  Regardless  of  performance  at any other point
during  the year,  the  Company's  right to receive a  performance  fee on those
accounts  will depend  entirely upon the  accounts'  performance  for the period
ended 31  December,  the date that the  performance  fee is measured and earned.
Accordingly, no performance fee had been recorded at 30 September 2007.

      Nine Month Results

      For the nine months ended 30 September  2007, a net loss of $10.4 million,
or $0.23 per share  (diluted) and $0.23 per share (basic) was recorded  compared
to a profit of $25.8  million  for the first nine  months of 2006,  or $0.56 per
share (diluted) and $0.56 per share (basic).

      Results  for  the  nine  months   ended  30   September   2007  include  a
non-recurring  gain on the sale of the  Company's  aircraft  of  $10.2  million,
post-tax, offset by non-recurring charges of approximately $18 million, taken in
the second  quarter of 2007,  related to an impairment of intangible  assets and
non-recurring  charges of approximately $7.8 million relating to agreements with
certain  employees,  reached  in the  first and third  quarters  of 2007,  whose
employment  with the Company  terminated in those  quarters.  The second quarter
non-recurring,  non-cash  charge of  approximately  $18.0 million  related to an
impairment of customer-related  intangible assets.  This impairment  reflected a
decrease  in assets  under  management,  the fees  from  which  were  supporting
customer-related  intangible assets per the Financial Accounting Standards Board
(SFAS No. 142).

      Cash  earnings  for the nine  months  ended 30  September  2007 were $26.0
million  (net  loss  of  $10.4  million   adjusted  to  include  $36.4  million,
representing  non-cash  income and expenses


                                                                               3


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 $0.56 per share (diluted).  In the same
period of the prior year,  cash earnings were $35.1 million (net income of $25.8
million  adjusted  for the  inclusion  of  $9.3  million  representing  non-cash
expenses of non-cash compensation, depreciation, amortization and other non-cash
charges on a tax-effected basis), or $0.77 per share (diluted).

      For the nine months ended 30 September 2007, there were 46,097,326  common
shares  outstanding on a weighted  average  diluted basis compared to 45,883,021
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  third  quarter  of 2007  was  5.2%,  pre-fee,  and  4.9%,
post-fee,  compared  to 2.0%  for the S&P  500.  For the  nine  months  ended 30
September  2007,  performance  in the  Composite  was 7.3%,  pre-fee,  and 6.5%,
post-fee,  compared to 9.1% for the S&P 500. For the twelve month period  ending
30 September 2007,  performance in the Composite was 14.8%,  pre-fee, and 13.6%,
post-fee, compared to 16.4% for the S&P 500.

      W.P.  Stewart's  five-year  performance  record  for the  period  ended 30
September  2007  averaged  13.8%,  pre-fee,  and  12.6%,  post-fee,   compounded
annually,  compared to an average of 15.5% for the S&P 500 in the same five-year
period.

      Performance in the W.P. Stewart International portfolio (ex United States)
for the third quarter of 2007 was 4.6%, pre-fee, and 4.4%, post-fee, compared to
2.2% for the MSCI EAFE Index.  Performance in the Global portfolio for the third
quarter of 2007 was 4.9%, pre-fee, and 4.7%, post-fee,  compared to 2.4% for the
MSCI World Index.  For the nine months ended 30 September  2007,  performance in
the  W.P.  Stewart  International  portfolio  was  13.2%,  pre-fee,  and  12.8%,
post-fee,  compared to 13.2% for the MSCI EAFE Index.  In the Global  portfolio,
performance for the nine months ended 30 September 2007 was 10.6%,  pre-fee, and
10.0%, post-fee, compared to 11.7% for the MSCI World Index.

      Performance in European portfolios for the third quarter of 2007 was 4.1%,
pre-fee, and 3.7%, post-fee, compared to 1.7% for the MSCI Europe Index. For the
nine months ended 30


                                                                               4


September 2007,  performance in the European portfolios was 20.6%,  pre-fee, and
19.3%, post-fee, compared to 14.4% for the MSCI Europe Index.

      Based on net asset  values,  performance  in the Stewart Asia Fund for the
third  quarter of 2007 was 6.3%  compared to 3.1% for the Dow Jones Asia Pacific
Index.  For the nine months ended 30 September  2007  performance in the Stewart
Asia Fund was 20.4% compared to 12.2% for the Dow Jones Asia Pacific Index.  The
Stewart Asia Fund is managed by the Company's affiliate, Bowen Asia.

      Monthly Performance Reporting

      Since  July 2007,  the  Company  has been  releasing  composite  portfolio
investment returns on a monthly basis. These returns are posted on the Company's
website at  www.wpstewart.com , usually within one week of month-end.  Below are
preliminary  indications of performance  for the month of October and for the 10
months ended 31 October 2007. These performance results are subject to change on
final reconciliation of all relevant data.

      Preliminary  indications are that performance in October 2007 for the U.S.
Equity Composite was -0.2%,  pre-fee,  and -0.3%,  post-fee.  This compares with
1.6% for the S&P 500. The year-to-date  performance for the Composite,  as of 31
October 2007 was 7.1%, pre-fee, and 6.2%, post-fee,  compared with 10.9% for the
S&P 500. For the twelve months ended 31 October 2007, the Composite was up 9.5%,
pre-fee, and 8.4%, post-fee, compared with 14.6% for the S&P 500 Index.

      Performance in the International  portfolios on a year-to-date basis as of
31 October 2007 was 16.7%, pre-fee, and 16.3%,  post-fee,  compared to 17.4% for
the MSCI EAFE Index. For the Global  portfolios  performance was 10.6%,  pre-fee
and 9.9%,  post-fee,  year-to-date as of 30 October 2007,  compared to 13.9% for
the MSCI  World  Index.  For the  European  portfolios  performance  was  24.9%,
pre-fee,  and 23.1%,  post-fee,  year-to-date as of 31 October 2007, compared to
19.5% for the MSCI Europe Index.

      The Stewart Asia Fund, managed by the Company's affiliate,  Bowen Asia and
which is included in the monthly performance reporting, posted returns of 26.8%,
year-to-date as of 31 October 2007, compared to 17.3% for its benchmark, the Dow
Jones Asia Pacific Index.


                                                                               5


      Assets Under Management

      Assets under  management  (AUM) at  quarter-end  were  approximately  $5.0
billion,  compared with $5.3 billion at the quarter ended 30 June 2007, and $8.3
billion reported at the quarter ended 30 September 2006.

      Total net flows of AUM for the quarter ended 30 September  2007 were -$553
million,  compared  with  -$476  million in the  comparable  quarter of 2006 and
- -$1,156 million in the second quarter of 2007.

      Total net flows of AUM for the nine  months  ended 30  September  2007 and
2006 were -$3,372 million and -$1,223 million, respectively.

      In the third  quarter of 2007,  net cash flows of existing  accounts  were
- -$93 million  compared with net cash flows of -$142 million in the third quarter
of 2006.  Net cash  flows of  existing  accounts  for the nine  months  ended 30
September 2007 were -$583 million  compared to -$380 million for the nine months
ended 30 September 2006.

      Net new flows (net contributions to our publicly available funds and flows
from new accounts  minus  closed  accounts)  were -$460  million for the quarter
compared to -$334 million for the same quarter of the prior year.  Net new flows
were -$2,789  million for the  nine-months  ending 30 September 2007 compared to
- -$843 million for the nine months ended 30 September 2006.

      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
10% to 20%, annually.

      Currently the "look-through"  earning power behind our clients' portfolios
remains solidly positive with portfolio  earnings per share growth on a trailing
four quarter basis as at 30 September 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.


                                                                               6


      Revenues and Profitability

      Revenues were $36.7  million for the quarter  ended 30 September  2007, an
increase of 32.9% from $27.6  million for the same quarter of 2006.  Included in
revenues  for the quarter  ended 30  September  2007 was a pre-tax gain of $18.5
million from the sale of the  Company's  aircraft.  Revenues for the nine months
ended  30  September  2007 and 2006  were  $84.8  million  and  $102.4  million,
respectively.

      The average gross  management fee was 1.05%,  annualized,  for the quarter
ended 30  September  2007 and 1.07%,  annualized,  for the nine months  ended 30
September  2007,  compared  to 1.09%  and  1.12%,  respectively,  in each of the
comparable periods of the prior year.

      Excluding performance fee based accounts, the average gross management fee
was 1.27%,  annualized,  for the quarter  ended 30  September  2007,  and 1.23%,
annualized,  for the nine months ended 30 September 2007,  compared to 1.23% and
1.25% in each of the comparable periods of the prior year.

      Total operating  expenses  decreased 9.0% to $21.5 million,  for the third
quarter 2007,  from $23.6  million in the same quarter of the prior year.  Total
operating  expenses  were $88.0  million  and $72.6  million for the nine months
ended 30 September 2007 and 2006, respectively.

      Operating  expenses in the third  quarter of 2007  include $2.0 million of
non-recurring  cash and  non-cash  charges  related to  agreements  with certain
employees whose employment with the Company terminated in the quarter.

      The increase in operating  expenses for the nine months ended 30 September
2007  compared  to  the  same  period  in  2006  substantially  relates  to  the
non-recurring,  non-cash  impairment  charge of $18.0  million  from the  second
quarter of 2007, as well as $7.8 million in non-recurring compensation expenses,
both cash and non-cash,  related to employees who  terminated  their  employment
with the Company during the first and third quarters of 2007.

      The  Company  expects  cash  compensation  to be in the range of $21 - $23
million  for 2007,  exclusive  of any  compensation  related  to the  receipt of
performance fees, compared with approximately $30 million in 2006.

      The non-cash  compensation  expense related to the restricted share grants
was approximately $4.6 million for the third quarter of 2007 (approximately $2.6
million in third  quarter  2006) and  approximately  $13.9  million for the nine
months  ended 30  September  2007  (approximately  $5.2  million for nine months
2006). This non-cash compensation expense is included in "employee


                                                                               7


compensation and benefits".  We expect non-cash  compensation expense related to
these restricted share grants to be at least $17.6 million for 2007.

      Pre-tax  income was $15.2 million for the quarter ended 30 September  2007
compared to $4.0 million in the comparable  quarter of the prior year. A pre-tax
loss of $3.2 million was  recorded  for the nine months ended 30 September  2007
compared  to a  pre-tax  profit  of  $29.7  million  for the nine  months  ended
September 30 2006.

      The Company's  provision for taxes for the quarter ended 30 September 2007
was $6.0 million, substantially reflecting the gain on the sale of the Company's
aircraft,  versus $0.5 million in the comparable  quarter of the prior year, and
was $7.2 million for the nine months ended 30 September 2007 versus $3.9 million
for the nine months ended 30 September 2006.

      Other Events

      The Company  paid 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 third quarter 2007 earnings release, W.P. Stewart
& Co.,  Ltd.  will host a conference  call on  Thursday,  1 November  2007.  The
conference  call will  commence  promptly at 9:15am  (EDT) and will  conclude at
10:00am (EDT).  Those who are interested in participating in the  teleconference
should dial 1-888-438-5448  (within the United States) or +719-325-2465 (outside
the United States). The conference ID is "W.P. Stewart" or "4491793".

      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 web-cast.

      The  teleconference  will be available for replay from Thursday 1 November
2007 at 12:00 noon (EDT) through Friday,  2 November 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 PIN number for accessing  this
replay is 4491793.

      You will be able to  access a replay  of the  Internet  broadcast  through
Thursday,  8 November 2007, on the Company's website at  www.wpstewart.com.  The
Company will respond to questions submitted by e-mail, following the conference.


                                                                               8


      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.

      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
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.


                                                                               9





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



                                                       For the Three Months Ended                           % Change From
                                             --------------------------------------------------   ---------------------------------
                                             Sept. 30, 2007    June 30, 2007    Sept. 30, 2006     June 30, 2007     Sept. 30, 2006
                                             ---------------  ----------------  ---------------   ----------------   --------------
                                                                                                       
Revenue:
  Fees                                       $   13,735,183   $    16,019,572   $   22,952,366            -14.26%          -40.16%
  Commissions                                     2,894,860         4,256,289        3,745,090            -31.99%          -22.70%
  Realized gain on sale of aircraft              18,464,963                 -                -                  -                -
  Realized and unrealized gains/(losses)
   on investments (1)                               981,738         1,300,243           19,913            -24.50%         4830.14%
  Interest and other (1)                            609,683           580,435          879,858              5.04%          -30.71%
                                             ---------------  ----------------  ---------------   ----------------   --------------

                                                 36,686,427        22,156,539       27,597,227             65.58%           32.94%
                                             ---------------  ----------------  ---------------   ----------------   --------------

Expenses:
  Employee compensation and benefits             11,162,970         9,487,651       11,858,821             17.66%           -5.87%
  Fees paid out                                   1,699,434         1,846,777        1,998,151             -7.98%          -14.95%
  Commissions, clearance and trading                403,276           726,948          617,937            -44.52%          -34.74%
  Research and  administration                    3,327,352         3,070,359        3,320,368              8.37%            0.21%
  Marketing                                       1,325,121         1,280,031        1,356,107              3.52%           -2.28%
  Depreciation and amortization                   1,441,374         1,448,278        1,620,681             -0.48%          -11.06%
  Impairment of intangible asset                          -        17,985,000                -                  -                -
  Other operating                                 2,101,628         2,860,020        2,797,460            -26.52%          -24.87%
                                             ---------------  ----------------  ---------------   ----------------   --------------
                                                 21,461,155        38,705,064       23,569,525            -44.55%           -8.95%
                                             ---------------  ----------------  ---------------   ----------------   --------------

Income before taxes                              15,225,272       (16,548,525)       4,027,702           -192.00%          278.01%

Provision for taxes                               6,006,852         1,263,722          490,831            375.33%         1123.81%
                                             ---------------  ----------------  ---------------   ----------------   --------------

Net income                                   $    9,218,420   $   (17,812,247)  $    3,536,871           -151.75%          160.64%
                                             ===============  ================  ===============   ================   ==============

Earnings per share:

Basic earnings per share                     $         0.20   $         (0.39)  $         0.08           -151.28%          150.00%
                                             ===============  ================  ===============   ================   ==============

Diluted earnings per share                   $         0.20   $         (0.39)  $         0.08           -151.28%          150.00%
                                             ===============  ================  ===============   ================   ==============


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 Nine Months Ended September 30,
                                                                   -------------------------------------------------------------
                                                                         2007                   2006                  %
                                                                   ------------------    -------------------  ------------------
                                                                                                          
Revenue:
  Fees                                                             $      50,816,699     $       75,928,182             -33.07%
  Commissions                                                             11,610,603             23,922,442             -51.47%
  Realized gain on sale of aircraft                                       18,464,963                      -                   -
  Realized and unrealized gains/(losses) on investments (1)                2,260,780                140,920            1504.30%
  Interest and other (1)                                                   1,630,446              2,389,200             -31.76%
                                                                   ------------------    -------------------  ------------------

                                                                          84,783,491            102,380,744             -17.19%
                                                                   ------------------    -------------------  ------------------

Expenses:
  Employee compensation and benefits                                      36,800,176             30,825,793              19.38%
  Fees paid out                                                            5,327,871              6,122,739             -12.98%
  Performance fee charge                                                           -              2,625,642                   -
  Commissions, clearance and trading                                       1,918,189              4,505,949             -57.43%
  Research and  administration                                             9,790,618             10,280,169              -4.76%
  Marketing                                                                4,169,310              4,556,123              -8.49%
  Depreciation and amortization                                            4,327,881              4,845,220             -10.68%
  Impairment of intangible asset                                          17,985,000                      -                   -
  Other operating                                                          7,698,772              8,877,800             -13.28%
                                                                   ------------------    -------------------  ------------------
                                                                          88,017,817             72,639,435              21.17%
                                                                   ------------------    -------------------  ------------------

Income before taxes                                                       (3,234,326)            29,741,309            -110.87%

Provision for taxes                                                        7,196,279              3,892,446              84.88%
                                                                   ------------------    -------------------  ------------------

Net income                                                         $     (10,430,605)    $       25,848,863            -140.35%
                                                                   ==================    ===================  ==================

Earnings per share:

Basic earnings per share                                           $           (0.23)    $             0.56            -141.07%
                                                                   ==================    ===================  ==================

Diluted earnings per share                                         $           (0.23)    $             0.56            -141.07%
                                                                   ==================    ===================  ==================


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 Nine Months Ended
                                            ---------------------------------------------------- -----------------------------
                                             Sept. 30, 2007   Jun. 30, 2007    Sept. 30, 2006    Sept. 30, 2007 Sept. 30, 2006
                                            ------------     -------------    -------------      -------------  -------------
                                                                                                 
Existing Accounts:
  Contributions                             $        58      $         56     $        100       $        197   $        597
  Withdrawals                                      (151)             (307)            (242)              (780)          (977)
                                            ------------     -------------    -------------      -------------  -------------
Net Flows of Existing Accounts                      (93)             (251)            (142)              (583)          (380)
                                            ------------     -------------    -------------      -------------  -------------
Publicly Available Funds:
  Contributions                                      13                19               17                107            129
  Withdrawals                                      (168)             (190)             (70)              (477)          (232)
Direct Accounts Opened                                7                28               27                150            111
Direct Accounts Closed                             (312)             (762)            (308)            (2,569)          (851)
                                            ------------     -------------    -------------      -------------  -------------
Net New Flows                                      (460)             (905)            (334)            (2,789)          (843)
                                            ------------     -------------    -------------      -------------  -------------

Net Flows of Assets Under Management        $      (553)     $     (1,156)    $       (476)      $     (3,372)  $     (1,223)
                                            ============     =============    =============      =============  =============


* The table above sets forth the total net flows of assets under  management for
the three months ended September 30, 2007, June 30, 2007 and September 30, 2006,
respectively,  and for the nine  months  ended  September  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.