Episode 51

ESG Investing – Seeking Higher Standards as Controversy Stirs

By:

Senior Market Analyst at Interactive Brokers

Cecile Fleckten, IBKR’s senior director and head of ESG and sustainability, discusses many of the challenges the ESG investing framework has been facing, along with how recent regulatory developments have not only been tackling, but also unearthing, many of the controversies with which the discipline has been contending. What does ESG and sustainability have in store in 5-10 years? Find out in this timely podcast!

Note: This podcast was recorded on November 16, 2022. 

Summary – IBKR Podcasts Ep. 51

The following is a summary of a live audio recording and may contain errors in spelling or grammar. Although IBKR has edited for clarity no material changes have been made.

Steven Levine

Hello, and welcome to IBKR Podcasts. I’m Steven Levine, senior market analyst at Interactive Brokers, and your host for today’s program. We’ll be speaking with Cecile Fleckten, IBKR’s senior director and head of ESG and sustainability, about the attention ESG and sustainability have been getting in the financial services sector, the influence it’s had on investing, as well as some of the advancements ESG has been making in the regulatory space, and what that means for the investing strategy.

So, welcome, Cecile!

Cecile Fleckten

Thanks Steven, great to be here.

Steven Levine

Thank you so much for taking the time to be here. Thanks for doing this. ESG and sustainability – at least from my research that led to the educational courses we have on Traders’ Academy and Coursera, for example – to my mind, it’s truly multifaceted, right? It’s got a long list of potential benefits, it seems …. [and] a lot of uncertainties, a lot of gray areas. So, I’m excited to fill some of that in with you here today. And I guess [the] first place to start would be: what exactly is ESG? I mean, I understand that it broadly stands for ‘environmental, social and governance,’ but I posed this question to a number of practitioners – these were portfolio managers, these were analysts, data science professionals – and their definitions … basically, they varied, right? There wasn’t one universally accepted standard definition at the time. I don’t know if there is one. Is there one? And if there isn’t, what risks or benefits do you think can be a consequence of not having one?

Cecile Fleckten

Thanks, Steven, that’s a very complex question today, and I’ll try to do my best to unpack it. So, you’re right, there’s no universal definition of ESG. However, there is more of an alignment of the tenants of ESG – as you cited, environmental, social, governance – and that has become an umbrella term, a catchall phrase, which essentially is a subset of topics that helps define how business approaches their impact – positive … negative – how they interface with society and environment at large…. It also overlays a lot of traditional functions, if you will, such as human resources, the risk management programs, internal audits…. There’s a whole bunch of overlays of different functions that encompasses the ESG, which has made it very, very confusing. I think originally the impetus around coining an ESG phrase was to help investors capture non-financial, non-traditional financial indicators, and it became this, unfortunately, ‘everything’ catch phrase.

Steven Levine

We sort of talked about this, I remember, in terms of the risks that are captured or structured within an ESG framework. And those risks pretty much seem to stand the test of time, or they’ve been around since, I suppose, the dawn of time. So, they’re really not new risks. If somebody was worried that a chemical company, for example, was going to incur huge litigation charges, for example, from polluting waters, they’d probably want to know or assess the risks that were involved, and would that hurt the chemical company’s bottom line, I suppose. But ESG and sustainability – this runs deeper than that, doesn’t it? I mean, there seem to be other kinds of concerns, and I’ve heard things like ‘values-based investing,’ ‘impact investing’, or other types …there seem to be a lot of different types of investment strategies depending on the investor’s own perspective, if you will, but can you color that in for us? Is ESG a framework that is something apart from, or different from, values-based investing? Is it presenting different kinds of risks for investors?

Cecile Fleckten

Great question, and I think you’ve hit the nail on the head in encapsulating there’s two different angles when it comes to ESG. So, as you mentioned, there’s a lot of areas that are traditional. They’ve been around for a long, long time, really based on risk management … when you think about environmental compliance or safety compliance. Those are areas that have been well under play with countries and frameworks, so that that’s not new, and a lot of that stemmed from catastrophic events that companies had to evolve from. So, when you think about wastewater, stormwater, soil contamination … remediation, you think about safety, human rights. Those are all areas that are not new. However, when you think of that values piece that you mentioned, the values investing … it is taking a look at a different angle on the investment piece and how you bring innovation to not just get rid of inefficiencies. So, if you think about sustainability in the sense of reducing waste, whether that’s emissions, whether that’s energy, whether that’s water, where you reduce materials and all of that hits your bottom line, it’s also thinking about the innovation side, and where can you invest to have more profit and also do greater good that can be in things like renewable energy or clean technology – better systems to help human capital. So, there is that other side of it that’s more on that opportunity side that’s not risk management based.

Steven Levine

I know these transitions, even within energy, had such a difficult time trying to remove certain toxins – like lead. Trying to remove lead from gasoline was an enormous feat. I think there was a gentleman named Clair Patterson who fought for years to try … and lead was in everything … lead was in paint, it was in your house paint, and kids were getting long-term diseases from this, and still he had such a hard time. It just reminds me of renewables today. And I’m not sure if it’s the same kind of exact removal of a harmful substance. It sounds like there’s a lot of studies, and a lot of research, that say that traditional energy sources are promoting a lot of harm to the climate, to the planet, to people … maybe in the same ways that lead did … in a different way, but parallel to that. Would you say that’s a fair assessment? Or are we looking at completely different kinds of transitional periods with respect to energy?

Cecile Fleckten

I think with respect to energy, there’s certainly unintended consequences when you look at new technology that hasn’t been tested. And you mentioned lead, which ubiquitously was everywhere, and fortunately there was a lot of laws that came into place to prevent lead contamination, especially to children. And the way we are going with green technology and renewable energy, it’s still evolving and trying to make sure that, likewise, the environmental impacts are considered when you think about lithium and mining for lithium salts, and when you think about the implications of the upstream supply chain with solar, for example, that, as you have seen probably in the last year, a lot of the exploitation in Xinjiang on labor and modern slavery has occurred, and has been occurring, as solar became more predominant for renewable energy. So, yes, there’s definitely unintended consequences. And what we’ve learned from growing up through that contamination and environmental compliance and enforcement is you can have, for all good intents and purposes, you can have a great, innovative product, but you also have to have the right framework to ensure that how you get to that product is done in a credible and good manner.

I think that as we explore nature-based solutions to solve some of our greatest issues, that is probably where we can find a resource to solve issues – yet without having that those lessons learned and corruption and abusive, or harmful, practices. However, I do think that we have a long ways to go, and fortunately we have had a lot of trials with different regulatory enforcement and frameworks that we have a better chance of approaching newer technologies and in the right way.

Steven Levine

Things have certainly changed, I would say, since the 19th century or early 20th century. And we do have a lot more exposure, don’t we, in terms of technology, and a keener awareness of what is happening – and if we don’t, we have a lot of motivation, it seems, among the investment community for transparency to want to know and to not be greenwashed, for example, or say that they’re going to do something that is positive for certain values that they may hold when they’re actually not doing it. So, I agree, I think that the direction is really going away from corruption and in a better framework, or a better light. I mean, those possibilities seem to have more of a spotlight on them.

Cecile Fleckten

You mentioned two key areas that I think it’s important to opine on, because it is the advent of technology … the speed of advancement and transparency … that has been this catalyst to improve business practices. I grew up through what some of us have considered on the what’s called the ‘boots to boardroom’ where I spent my first ten years in the field doing all kinds of environmental and social field work outside of the office. And with that, as you touched upon, the availability of data and transparency really shaped how businesses reacted. So, I’ll give an example. When I was based in Southeast Asia, doing a lot of social and environmental audits and going to Western corporate companies and their facilities and factories in places like Myanmar or Malaysia, Philippines, Indonesia, Thailand …. I was very shocked to see the dichotomy of what was presented in their sustainability report versus what was happening on the ground.

I think, certainly the technology piece … social media … being able to have more of a voice … has accelerated the pace of how fast businesses have to adopt better practices.

Surprisingly, there were countries that, despite not having any regulatory … environmental or social laws … that actually had really good practices, which comes at a big surprise. But I do think that it is important to think about the complex supply chains, where there’s resources, and what kind of markets can develop. Say, for example, if you move away from polysilicon in Northwest China and Xinjiang, and you look for that resource in another place – there’s still a lot of heavy infrastructure that goes into … you’re essentially turning sand into glass in the solar industry … and with the solar industry, there’s already supply chain … if you’re ordering panels in the U.S., a lot of that manufacturing – not the upstream – but a lot of the manufacturing of the panels already occurs in Southeast Asia. That’s only if you’re delivering to the U.S. The supply chain for Europe and Asia for solar is very, very different and won’t follow this same process that happens for delivery into the U.S. But I do believe that where there’s risk, there’s certainly opportunity. It’s just that natural resources is very difficult in building that infrastructure around, so co-operation of the governments having the right regulatory policies, and then also having the right incentives for private investment, to help tackle some of these issues, it’s very important.

Steven Levine

It sounds like a huge shift as well, in terms of, I suppose, international affairs or political alignments. I mean, if our infrastructure, in terms of our energy, is going to be reliant in some huge way on solar, and that solar is being produced in another country … or dependent on … or reliant on another country, then I suppose our entire economic well-being is tethered to our relations with that country or would have to be.

Cecile Fleckten

I think with the trade agreement, certainly, and it’s also trying to understand the debt markets … project financing, and with that comes the sustainable development around these larger projects and investments. So, I think that’s important. In Asia, in particular, I do have to say they have done a good job, when you think back to how sustainable banking came into play through equator principles back in 2010, and following through on IFC [International Finance Corporation] performance standards, which essentially is a high standard for doing larger capital-intensive projects. So, I think there’s quite a lot of lessons learned that Western societies can learn from Asia, when you think about some of the ways that they’ve evolved in creating frameworks around environmental and social issues, and we need to continue to take those lessons learned and develop the right policies.

Steven Levine

It’s funny that you mentioned these debt-financed projects, because there’s a whole now slew of bonds and fixed-income products that are focused on ESG-related concerns. There’s social bondsgreen bonds have been a huge thing for some time now … but also sustainability-linked bonds and sustainability bonds – and I understand that there’s a difference between those two. There’s gender bonds. There’s a whole spectrum of different kinds of projects that are being financed within this framework. There have been questions about it, because there’s no formal regulatory policy around the proceeds being used from these projects. You can say it’s a ‘green bond,’ for example, and it abides by certain rules or guidelines, but not regulatory, right? There’s no law that dictates them. But also, they’re really unprecedented in terms of the projects that they’re aiming to achieve to do. I mean [an] entire, say, infrastructure of a public transport system to go green, for example, in Germany. And so Germany, say, would have a great deal of green bonds from their government to fund their federal railway.  But then there’s also social bonds that are meant to do, say, certain social projects that rely on the revenues to pay back the bondholders. So, the bondholders buy these. They have to get their debt service paid. And usually with a revenue bond, there’s all sorts of feasibility studies. But these sound like certain unprecedented types of projects. So, how can you really be sure – one, that they’re not being greenwashed and two, that they’re able to actually produce that revenue to pay back these bondholders? And if that’s something we could dive into?

Cecile Fleckten

That’s a great question, and we’re talking about here the social projects funded with debt, such as ones that are related to affordable housing, for example, or food security or socioeconomic advancement – you mentioned gender … affordable and basic infrastructure, schools, roads, hospitals, R&D projects. And fortunately, although there’s not a lot of regulation, there are standards for social bonds such as the International Capital Market Association, ICMA. They’ve set voluntary guidelines for transparency and unified reporting. They have environmental objectives, and they also created some framework around estimating impact. It’s important to note that the sustainable bond market, obviously, is still a fraction of the broader fixed-income market, and clearly these investments carry more liquidity risk and overconcentration risk to certain issuers, whether that’s in different sectors or regions. And, so, I believe it is very important to have sophisticated asset managers … investment managers that are equipped and experienced in managing these risks, and obviously to target risk-adjusted returns. I mentioned earlier, and this is where it’s important to look at what’s been done in the past, because there is a very similar common ground here when you think about international project financing. And that’s where equator principles came into play, because it was for the same reasons. Where do you have these big capital-intensive projects that you rely on future revenues to pay back these giant loans? So, to answer your question on ‘how do you know that the money is being used for these projects,’ and there is a good framework, and that does speak to the experience of those investment managers, but using the framework that’s already been developed. For example, in equator principles there is a requirement to have independent environmental and social audits that are done – not by the sponsor of the project, not their consultant, but to have an actual separate, independent engineer and an independent environmental and social specialist come and do audits. They also require environmental and social management systems. Where you have those investment firms that have that background and knowledge, they will have that understanding on how to create the right framework to have the checks and balances to ensure that that money is being used for the right purpose.

Steven Levine

It’s great to know that there is some sound framework or community, I suppose, that is governing the project at hand and making sure that it is doing what they say that they’re going to do – they’re following through on the basic vision of it. There has been a lot of controversy though, hasn’t there, about ESG investing – that the strategy, itself, Is a form of greenwashing. What do you say to people who might be swayed into believing that might be the case?

Cecile Fleckten

I think this has been a pivotal year for ESG investing, because there’s been a lot of controversy, and there’s also been a lot of confusion on the definitions … the ratings. You might have seen the headlines on the recent investigations with Goldman Sachs, and Deutsche Bank’s asset manager DWSBNY Mellon on the ESG marketing of their funds. But it comes to no surprise in the sense that because there’s not a universal definition, and ESG can mean different things to different people, there will be this bit of this tension on – is it greenwashing? Is it a PR exercise or is there real value in having these ESG labels? So, I’m a bit ambivalent in the sense that I do believe that there is merit to focusing on that sustainability piece and essentially creating the right approach on how you do sustainable investing. It’s two different things where the ‘how’ is doing it in the right framework and the actual outcome, whether that’s the product or the service, is sustainable in that definition. And it is, again, very, very confusing. So, unfortunately there will continue to be some risk of greenwashing, but the good news today is that there’s a lot of attention, a lot of focus, a lot of new regulations, a lot of areas where reporting and disclosure is becoming more pronounced than ever before.

Steven Levine

Yes, yes, and the rules on that reporting and disclosure … I suppose that they’ve got internal policies as well that are being governed to determine on their end that what they’re reporting and disclosing is accurate. I guess there’s some penalties for that?

Cecile Fleckten

Yes, I think so. I think that it’s accurate, and it’s also, I think, in the U.S. has become very politicized, and we’re in our election season. There is a whole bunch of consternation around the different views, and it’s unfortunately created a whole other level of attention on ESG with what was intentionally meant to be trying to advance areas that we traditionally didn’t really think about or consider in business strategy.

Steven Levine

It also seems to get tied into just very negative things, unfortunately, it seems. Climate activists, for example, and throwing paint at paintings, and it just … it seems like people who might consider ESG might think, ‘Oh, this is just in the same camp as what those people are doing in those museums, or that’s a reflection of it,’ but there is a very distinct boundary or parameter for investors – to look at ESG as a framework for transitioning, and, I suppose, the risks and benefits in there are – how are these companies that they’re invested in transitioning in ways that will benefit the company and also the ecosystem in which they operate? So, a sort of societal impact in the long-term. So, investors are not only investing in the company, and in their well-being – financially, for the company – but the financial well-being for the entire ecosystem and community in which they thrive.

Cecile Fleckten

Yeah, I believe so, and if you look at just some of the sheer numbers that are out there – when you think about investing in where you have climate change impact and looking at those new technologies…. The Net Zero alliance, for example. Those net zero asset managers … that’s some 66 trillion in assets under management … over 290 asset managers there. And so, I think that’s very significant, and it does … number one, there’s a lot of investment opportunity there; and number two, it’s also the ESG aspects speak to, again, good controls, having the right framework, management systems. So, I think that that’s important to highlight is there’s still a lot of positives, when you consider the ESG investing side of things.

Steven Levine

You did mention earlier about reporting and transparency and regulations, and so, I’d be really keen to know …. it’s been some time…. what are regulators doing today that makes you optimistic about advancing ESG into a more formalized strategy that people can feel more ‘comfortable’ with?

Cecile Fleckten

I think there’s two parts of that to that question, and there’s a lot of emphasis now on disclosures and reporting and having a bit more consistency in reporting. The EU right now is leading and coming out with all kinds of directives they’ve worked on in the last few years … the sustainable finance reporting directive [Sustainable Finance Disclosure Regulation (SFDR)] … just this week, the Corporate Sustainability Reporting Directive [CSRD] passed. There’s taxonomy law … TCFD, the Task Force on Climate-related [Financial] Disclosures, and the SEC’s rule on climate disclosure rules, which is proposed now and should finalize. So, I think there is a lot of the input-based reporting mandates. I think that that is important to set some standards … a bit of a consolidation to get rid of inconsistency. So, it’s great to see what’s happening with IFRS, which has two sustainability reporting boards now. And it’s also, if you think about the UK, their Financial Conduct Authority has a proposal to introduce investment product sustainability labels, which is very important. But if I have to fast-forward and think about what would be even more effective, because maybe not so much the input and the disclosure-related piece – it is good to have that, don’t get me wrong – but I would like to see more outcome-based regulatory policies really driving the outcome side. So, I just moved from California, and there is a lot of policies around pushing consumers into the direction of clean technology and just with the, for example, having cars that are no longer using traditional combustion. So, I think right now it is focused on disclosures and enforcement and attention on disclosures, input-based, but hopefully in the future [it] will be more of that outcome-based.

Steven Levine

What do you think is hampering that approach to outcome-based policy? Are you thinking that maybe there’s a cautionary tale to be had here and not to go too far to push an outcome? Is there just too much resistance to that, do you think? I guess from a political will? Or even among the people who would be making the decision as to phasing out all combustion engine vehicles and only having electric cars to choose from?

Cecile Fleckten

I think it touches up on what we talked about earlier in some of the newer technologies. It’s [that] the unintended consequences aren’t known yet. Having that infrastructure, having the right resources to mine from is still pretty nascent, and if you push an outcome-based [policy], you certainly have to understand what those unintended consequences could be. And is society ready for that?

Steven Levine

Like UFOs. They kept that under wraps for so long, and now they just can’t do it anymore, right? Nobody seems shocked. It’s amazing.

Cecile Fleckten

I think there is intelligent life. The fact that they haven’t reached out to us means there is intelligent life out there.

Steven Levine

No, it’s really interesting, and it’s really great. And you did mention that you can see regulations perhaps unfolding in maybe … in the same way [as in Europe currently] or … maybe Europe is an indication of what we might expect here in terms of advancements in the space of ESG? But let’s look 5-10 years from now. So, investors who are really interested in this and are wondering whether they should stay in this ESG space and continue to make their, say, fundamental assessments based within an ESG framework or even technical now I suppose, because there’s a lot of data that can be used to determine certain signals as to whether a company is meeting values, for example, that they hold or getting too much negative attention one way or another. But what does it look like in 5-10 years in your view? I mean what kind of environment is being marketed, for example, when people hear about ESG investing or sustainability?  What do you think is going to be the landscape?

Cecile Fleckten

We’ve seen, from all of the different ESG dimensions … I think we’ve had a really eye-opening year. Thinking about what we’re going through, and so far as climate breakdown, for example, there’s probably every continent now has seen some kind of climate disaster, whether it be flooding or the severe wildfires. So, I think’s that on the ‘E’ side of the equation, I think it’s pretty united now compared to previous years. And looking forward in five years … coming out the gates now, actually this week out of COP 27 in Egypt, there is some strong emphasis on looking at that – the climate change piece, looking specifically at loss and damage, how to deal with that, trying to accelerate private finance, get a lot of the emerging markets on board and setting up their policies, having the right standards for disaster mitigation when it comes to insurance. So, I think that train is well underway. I think for, on the ‘S’ side, I think that one’s a little bit more complicated. There’s certainly human rights issues that are coming out now from – just even the U.S.’s pull-out of Afghanistan, what’s happening with the war in the Ukraine. looking at the issues now in Haiti. So, there’s a lot of dislocation and transmigration of people. Just a few days ago we hit 8 billion in the world population.

Steven Levine

I saw that.

Cecile Fleckten

So, we have to think strongly about the innovation around food security – not just looking at climate, but also what … you did a spot on food bioengineering … and that’s become very, very important.

Steven Levine

Bioengineered food, that’s right. Ten billion people by 2050, I understand, or something in that ballpark.

Cecile Fleckten

That’s right, that’s right, and India surpassing China soon.

Steven Levine

In that podcast we talked about food insecurity in areas where we have enough food to actually feed certain populations, but we can’t get the food to them, right? There are all sorts of issues there. There’s economic turmoil. There’s all sorts of barriers that just prevent a box from going over a border.

Cecile Fleckten

There’s corruption issues. We had a food for oil program many years ago in the Middle East … that didn’t work.

Steven Levine

I remember that.

Cecile Fleckten

So, I think there’s certainly a lot of complex issues when it comes to the ‘S’ side of things. There’s also, when we think about the human capital side, it’s not only thinking about benefits and how to promote diversity and looking at pay gap, it’s also understanding coming out of the pandemic and many, many years from now, the mental health issues … and the medical benefits, how does that work? So many complex issues just over the span over the next few years. I think it’ll look very differently, hopefully, in 10 years. I’m a bit more hopeful. But I think for the next five years, it’s going to be a bit of a tumultuous time in the sustainability space.

Steven Levine

But there must be certain businesses or industries within this environment that are going to be unrecognizable, I can imagine, over the course of 5-10 years, as these changes are taking place. I don’t know what that will be. I know you were talking about outcome-driven types of policy like, say, in California and electric vehicles, for example. The auto industry then is bound to face some completely different product lines, right, and the way that they manufacture these vehicles are going to involve ecosystems that are going to be completely different as well. Recycling the batteries, for example, we could do that. We have grid storage, we need to have all this electricity somehow stored in a place where it can be accessed and used, and centralized and protected, right? So, there’s a lot, a lot of things that get tied together, and for investors looking at these transitions, they do need to rely on some kind of source that guides them through all of the changes that are taking place. Do you think that there’s really a place for them to go? They could come here, right? We have great research. But what do you think?

Cecile Fleckten

I think that’s a good point. I think certainly there’s a lot of interesting industries that have been forced to transform. Will they be unrecognizable in 10 years? I’m not sure. I do think that there’s a lot of opportunity, and we’re starting to see that transition with [the] oil and gas industry and how much capex they put into renewable energy, for example. And I think that when we think about the other areas, such as agriculture and methane emissions, there’s a lot of innovative investments that are going into the agricultural space, and that’s tied to having that food security. But it will continuously be dependent on how fast countries collaborate, and work together, to have more of that unification to solve some of these issues. I think the airline and transport industry will look different very, very different as they start to look at more of the innovative technologies, and I’m personally hoping to see more aerial taxis when we think about how drones have evolved….

Steven Levine

Anything to get out of the New York City congestion, that would be great, and that would beat a lot of congestion costs, too … the taxis are raising their prices now for rush hour traffic. So yes, yes, that’s an outcome-based policy I would definitely vote for.

Cecile Fleckten

That’s right, that’s right. So, I think there’s some exciting times when you think about 10 years from now. So, I think that we’ll see what happens in the next five years. It’s very interesting to hear what will come out from COP 27. There’s now A big, big focus on nature-based solutions, so I think that’s also very exciting. I think there’s other industries that also need to advance, especially when you think about specialty chemicals and what that has to do for circular economy. Those are emerging areas and full of investment opportunity.

Steven Levine

That’s awesome. That’s great. I mean, this has been really, really great. Is there anything else that you’d like to inform people about ESG and sustainability from your journey through ESG and sustainability, or anything else you’d like to add?

Cecile Fleckten

I’m hoping that in a few years we no longer will be so focused on that term ‘ESG’. I’m hoping that it will be integrated. It’s not its own separate identity, and sustainability is also, likewise, is just regular BAU [business as usual] and is integrated into how businesses think about their success and their profit and their future. Because, I think, unnecessarily ESG has been this focus of controversy when it doesn’t have to be. And setting aside all the differences and the confusion, I think it’s coming from a good place and trying to essentially bring more impact to society and also help solve some of the biggest problems that we face.

Steven Levine

It sounds really ideal. I mean, really, it sounds to me – and I could be wrong here – but it sounds like it’s evolving towards a common sense approach to doing business that has a benefit for everyone in mind and that actually delivers and follows through on that benefit.

Cecile Fleckten

I agree.

Steven Levine

That’s really terrific. Cecile, thank you again for taking the time to do this. I think this was really fascinating.

Cecile Fleckten

Thanks, Steven. My pleasure.

Steven Levine

You can learn more market commentary, analysis, and insights about ESG and sustainability at IBKR Traders’ Insight at tradersinsight.news. Lots of fascinating articles there that delve into a wide range of information. We also have courses on Traders’ Academy, as well as through Coursera, as we mentioned. Also, check out our webinars at ibkrwebinars.com, and for those interested in making trading decisions aligned with your values, IBKR offers the IMPACT app.

And until next time I’m Steven Levine for Interactive Brokers.

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