examples include accounts maintained under the uniform gift to minors act ( ugma ) or uniform transfer to minors act ( utma ) , guardianship , conservatorship and trust arrangements and pension or profit plan for small business accounts . brokerage accounts  accounts maintained by the company on behalf of clients for securities brokerage activities . the primary types of brokerage accounts are cash accounts , margin accounts , ira accounts and beneficiary accounts . futures accounts are sub-accounts associated with a brokerage account for clients who wish to trade futures and or options on futures . cash accounts  brokerage accounts that do not have margin account approval . client assets  the total value of cash and securities in brokerage accounts . client cash and money market assets  the sum of all client cash balances , including client credit balances and client cash balances swept into insured deposit accounts or money market mutual funds . client credit balances  client cash held in brokerage accounts , excluding balances generated by client short sales on which no interest is paid . interest paid on client credit balances is a reduction of net interest revenue . client credit balances are included in payable to clients on our consolidated balance sheets . client margin balances  the total amount of cash loaned to clients in margin accounts . such loans are secured by client assets . interest earned on client margin balances is a component of net interest revenue . client margin balances are included in receivable from clients , net on our consolidated balance sheets . daily average revenue trades ( darts )  total trades divided by the number of trading days in the period . this metric is also known as average client trades per day . ebitda  ebitda ( earnings before interest , taxes , depreciation and amortization ) is a non-gaap financial measure . we consider ebitda to be an important measure of our financial performance and of our ability to generate cash flows to service debt , fund capital expenditures and fund other corporate investing and financing activities . ebitda is used as the denominator in the consolidated leverage ratio calculation for covenant purposes under our holding company 's senior revolving credit facility . ebitda eliminates the non-cash effect of tangible asset depreciation and amortization and intangible asset amortization . ebitda should be considered in addition to , rather than as a substitute for , pre-tax income , net income and cash flows from operating activities . eps excluding amortization of intangible assets  earnings per share ( eps ) excluding amortization of intangible assets is a non-gaap financial measure . we define eps excluding amortization of intangible assets as earnings ( loss ) per share , adjusted to remove the after-tax effect of amortization of acquired intangible assets . we consider eps excluding amortization of intangible assets an important measure of our financial performance . amortization of acquired intangible assets is excluded because we believe it is not indicative of underlying business performance . eps excluding amortization of intangible assets should be considered in addition to , rather than as a substitute for , gaap earnings per share . eps from ongoing operations  eps from ongoing operations is a non-gaap financial measure . we define eps from ongoing operations as earnings ( loss ) per share , adjusted to remove any significant unusual gains or charges . we consider eps from ongoing operations an important measure of the financial performance of our ongoing business . unusual gains and charges are excluded because we believe they are not likely to be indicative of the ongoing operations of our business . eps from ongoing operations should be considered in addition to , rather than as a substitute for , gaap earnings per share . fee-based investment balances  client assets invested in money market mutual funds , other mutual funds and company programs such as advisordirect ® and amerivest , ® on which we earn fee revenues . fee revenues earned on these balances are included in investment product fees on our consolidated statements of income . funded accounts  all open client accounts with a total liquidation value greater than zero . 26 futures accounts  sub-accounts maintained by the company on behalf of clients for trading in futures and or options on futures . each futures account must be associated with a brokerage account . futures accounts are not counted separately for purposes of the company 's client account metrics . insured deposit account  the company is party to an insured deposit account ( ida ) agreement with td bank usa , n.a . ( td bank usa ) , td bank , n.a . and the toronto-dominion bank ( td ) . under the ida agreement , td bank usa and td bank , n.a . ( together , the depository institutions ) make available to clients of the company fdic-insured money market deposit accounts as either designated sweep vehicles or as non-sweep deposit accounts . the company provides marketing , recordkeeping and support services for the depository institutions with respect to the money market deposit accounts . in exchange for providing these services , the depository institutions pay the company an aggregate marketing fee based on the yield earned on the client ida assets , less the actual interest paid to clients , a servicing fee to the depository institutions and the cost of fdic insurance premiums . interest rate-sensitive assets  consist of spread-based assets and client cash invested in money market mutual funds . investment product fees  revenues earned on fee-based investment balances . investment product fees include fees earned on money market mutual funds , other mutual funds and through company programs such as advisordirect ® and amerivest ® . story_separator_special_tag significant judgment is required in making these estimates , and the actual cost of resolving a matter may ultimately differ materially from the amount accrued . valuation of guarantees we enter into guarantees in the ordinary course of business , primarily to meet the needs of our clients and to manage our asset-based revenues . we record a liability for the estimated fair value of the guarantee at its inception . if actual results differ significantly from these estimates , our results of operations could be materially affected . for further details regarding our guarantees , see the following sections under item 8 , financial statements and supplementary data  notes to consolidated financial statements : guarantees under note 15  commitments and contingencies and insured deposit account agreement under note 19  related party transactions . results of operations conditions in the u.s. equity markets significantly impact the volume of our clients ' trading activity . there is a direct correlation between the volume of our clients ' trading activity and our results of operations . we can not predict future trading volumes in the u.s. equity markets . if client trading activity increases , we expect that it would have a positive impact on our results of operations . if client trading activity declines , we expect that it would have a negative impact on our results of operations . changes in average balances , especially client margin , credit , insured deposit account and mutual fund balances , may significantly impact our results of operations . changes in interest rates also significantly impact our results of operations . we seek to mitigate interest rate risk by aligning the average duration of our interest-earning assets with that of our interest-bearing liabilities . we can not predict the direction of interest rates or the levels of client balances . if interest rates rise , we generally expect to earn a larger net interest spread . conversely , a falling interest rate environment generally would result in our earning a smaller net interest spread . financial performance metrics pre-tax income , net income , earnings per share and ebitda are key metrics we use in evaluating our financial performance . ebitda is a non-gaap financial measure . we consider ebitda to be an important measure of our financial performance and of our ability to generate cash flows to service debt , fund capital expenditures and fund other corporate investing and financing activities . ebitda is used as the denominator in the consolidated leverage ratio calculation for covenant purposes under our holding company 's senior revolving credit facility . ebitda eliminates the non-cash effect of tangible asset depreciation and amortization and intangible asset amortization . ebitda should be considered in addition to , rather than as a substitute for , pre-tax income , net income and cash flows from operating activities . 31 the following table sets forth ebitda in dollars and as a percentage of net revenues for the periods indicated , and provides reconciliations to net income , which is the most directly comparable gaap measure ( dollars in millions ) : replace_table_token_6_th our ebitda increased 17 % for fiscal 2013 compared to fiscal 2012 , primarily due to a 5 % increase in net revenues and $ 57 million of net gains on investments , while operating expenses were effectively unchanged . the increase in net revenues was primarily due to an 8 % increase in transaction-based revenues and a 3 % increase in asset-based revenues , partially offset by a 13 % decrease in other revenues . detailed analysis of our operating results is presented later in this discussion . our diluted earnings per share was $ 1.22 , $ 1.06 and $ 1.11 for fiscal years 2013 , 2012 and 2011 , respectively . higher ebitda was partially offset by a higher effective income tax rate for fiscal 2013 , resulting in a 15 % increase in net income compared to fiscal 2012. our effective income tax rate for fiscal 2012 was significantly lower than normal , primarily due to $ 19 million of favorable resolutions of state income tax matters and a $ 3 million benefit resulting from the reversal of a valuation allowance related to a capital loss carryover . these items favorably impacted diluted eps for fiscal 2012 by approximately four cents per share . based on our expectations for net revenues and expenses , we expect diluted earnings per share to range from $ 1.20 to $ 1.40 for fiscal year 2014. details regarding our fiscal year 2014 expectations for net revenues and expenses are presented later in this discussion . operating metrics our largest sources of revenues are asset-based revenues and transaction-based revenues . for fiscal 2013 , asset-based revenues and transaction-based revenues accounted for 55 % and 42 % of our net revenues , respectively . asset-based revenues consist of ( 1 ) net interest revenue , ( 2 ) insured deposit account fees and ( 3 ) investment product fees . the primary factors driving our asset-based revenues are average balances and average rates . average balances consist primarily of average client margin balances , average segregated cash balances , average client credit balances , average client insured deposit account balances , average fee-based investment balances and average securities borrowing and lending balances . average rates consist of the average interest rates and fees earned and paid on such balances . the primary factors driving our transaction-based revenues are total client trades and average commissions and transaction fees per trade . we also consider client account and client asset metrics , although we believe they are generally of less significance to our results of operations for any particular period than our metrics for asset-based and transaction-based revenues . asset-based revenue metrics we calculate the return on our interest-earning assets and our insured deposit account balances using a measure we refer to as net interest margin . net interest margin

liquidity and capital resources as a holding company , td ameritrade holding corporation conducts substantially all of its business through its operating subsidiaries , principally its broker-dealer subsidiaries . we have historically financed our liquidity and capital needs primarily through the use of funds generated from subsidiary operations and from borrowings under our credit agreements . we have also issued common stock and long-term debt to finance mergers and acquisitions and for other corporate purposes . our liquidity needs during fiscal 2013 were financed primarily from our subsidiaries ' earnings , cash on hand and our parent company 's revolving credit facility . we repaid $ 250 million of 2.950 % senior notes due december 1 , 2012 with cash on hand . we financed our payment of a $ 0.50 per share special cash dividend on december 31 , 2012 by borrowing $ 275 million on our parent company 's revolving credit facility , which we repaid in full during fiscal 2013. we funded a portion of the repayment in part using $ 69 million of cash consideration we received in connection with knight capital group , inc. 's july 1 , 2013 merger with getco holding company , llc . for more information regarding the knight-getco merger , see note 7  investments available-for-sale under item 8 , financial statements and supplementary data  notes to consolidated financial statements . we plan to finance our capital and liquidity needs in fiscal 2014 primarily from our subsidiaries ' earnings , cash on hand , and borrowings on our parent company and or broker-dealer revolving credit facilities . dividends from our subsidiaries are the primary source of liquidity for the parent company . some of our subsidiaries are subject to requirements of the securities and exchange commission ( sec ) , the financial industry regulatory authority ( finra ) , the commodity futures trading commission ( cftc ) , the national futures association ( nfa ) and other regulators relating to liquidity , capital standards and the use of client funds and securities , which may limit funds available for the payment of dividends to the parent company .


 Write a concise suspicious activity report of the following text delimited by triple backquotes. Return your response as a formal report which covers the key points highlighting the location,dates,entity names and account holder information in chronological order of the text.
     ```liquidity and capital resources as a holding company , td ameritrade holding corporation conducts substantially all of its business through its operating subsidiaries , principally its broker-dealer subsidiaries . we have historically financed our liquidity and capital needs primarily through the use of funds generated from subsidiary operations and from borrowings under our credit agreements . we have also issued common stock and long-term debt to finance mergers and acquisitions and for other corporate purposes . our liquidity needs during fiscal 2013 were financed primarily from our subsidiaries ' earnings , cash on hand and our parent company 's revolving credit facility . we repaid $ 250 million of 2.950 % senior notes due december 1 , 2012 with cash on hand . we financed our payment of a $ 0.50 per share special cash dividend on december 31 , 2012 by borrowing $ 275 million on our parent company 's revolving credit facility , which we repaid in full during fiscal 2013. we funded a portion of the repayment in part using $ 69 million of cash consideration we received in connection with knight capital group , inc. 's july 1 , 2013 merger with getco holding company , llc . for more information regarding the knight-getco merger , see note 7  investments available-for-sale under item 8 , financial statements and supplementary data  notes to consolidated financial statements . we plan to finance our capital and liquidity needs in fiscal 2014 primarily from our subsidiaries ' earnings , cash on hand , and borrowings on our parent company and or broker-dealer revolving credit facilities . dividends from our subsidiaries are the primary source of liquidity for the parent company . some of our subsidiaries are subject to requirements of the securities and exchange commission ( sec ) , the financial industry regulatory authority ( finra ) , the commodity futures trading commission ( cftc ) , the national futures association ( nfa ) and other regulators relating to liquidity , capital standards and the use of client funds and securities , which may limit funds available for the payment of dividends to the parent company .
```    
 Suspicious Activity Report : examples include accounts maintained under the uniform gift to minors act ( ugma ) or uniform transfer to minors act ( utma ) , guardianship , conservatorship and trust arrangements and pension or profit plan for small business accounts . brokerage accounts  accounts maintained by the company on behalf of clients for securities brokerage activities . the primary types of brokerage accounts are cash accounts , margin accounts , ira accounts and beneficiary accounts . futures accounts are sub-accounts associated with a brokerage account for clients who wish to trade futures and or options on futures . cash accounts  brokerage accounts that do not have margin account approval . client assets  the total value of cash and securities in brokerage accounts . client cash and money market assets  the sum of all client cash balances , including client credit balances and client cash balances swept into insured deposit accounts or money market mutual funds . client credit balances  client cash held in brokerage accounts , excluding balances generated by client short sales on which no interest is paid . interest paid on client credit balances is a reduction of net interest revenue . client credit balances are included in payable to clients on our consolidated balance sheets . client margin balances  the total amount of cash loaned to clients in margin accounts . such loans are secured by client assets . interest earned on client margin balances is a component of net interest revenue . client margin balances are included in receivable from clients , net on our consolidated balance sheets . daily average revenue trades ( darts )  total trades divided by the number of trading days in the period . this metric is also known as average client trades per day . ebitda  ebitda ( earnings before interest , taxes , depreciation and amortization ) is a non-gaap financial measure . we consider ebitda to be an important measure of our financial performance and of our ability to generate cash flows to service debt , fund capital expenditures and fund other corporate investing and financing activities . ebitda is used as the denominator in the consolidated leverage ratio calculation for covenant purposes under our holding company 's senior revolving credit facility . ebitda eliminates the non-cash effect of tangible asset depreciation and amortization and intangible asset amortization . ebitda should be considered in addition to , rather than as a substitute for , pre-tax income , net income and cash flows from operating activities . eps excluding amortization of intangible assets  earnings per share ( eps ) excluding amortization of intangible assets is a non-gaap financial measure . we define eps excluding amortization of intangible assets as earnings ( loss ) per share , adjusted to remove the after-tax effect of amortization of acquired intangible assets . we consider eps excluding amortization of intangible assets an important measure of our financial performance . amortization of acquired intangible assets is excluded because we believe it is not indicative of underlying business performance . eps excluding amortization of intangible assets should be considered in addition to , rather than as a substitute for , gaap earnings per share . eps from ongoing operations  eps from ongoing operations is a non-gaap financial measure . we define eps from ongoing operations as earnings ( loss ) per share , adjusted to remove any significant unusual gains or charges . we consider eps from ongoing operations an important measure of the financial performance of our ongoing business . unusual gains and charges are excluded because we believe they are not likely to be indicative of the ongoing operations of our business . eps from ongoing operations should be considered in addition to , rather than as a substitute for , gaap earnings per share . fee-based investment balances  client assets invested in money market mutual funds , other mutual funds and company programs such as advisordirect ® and amerivest , ® on which we earn fee revenues . fee revenues earned on these balances are included in investment product fees on our consolidated statements of income . funded accounts  all open client accounts with a total liquidation value greater than zero . 26 futures accounts  sub-accounts maintained by the company on behalf of clients for trading in futures and or options on futures . each futures account must be associated with a brokerage account . futures accounts are not counted separately for purposes of the company 's client account metrics . insured deposit account  the company is party to an insured deposit account ( ida ) agreement with td bank usa , n.a . ( td bank usa ) , td bank , n.a . and the toronto-dominion bank ( td ) . under the ida agreement , td bank usa and td bank , n.a . ( together , the depository institutions ) make available to clients of the company fdic-insured money market deposit accounts as either designated sweep vehicles or as non-sweep deposit accounts . the company provides marketing , recordkeeping and support services for the depository institutions with respect to the money market deposit accounts . in exchange for providing these services , the depository institutions pay the company an aggregate marketing fee based on the yield earned on the client ida assets , less the actual interest paid to clients , a servicing fee to the depository institutions and the cost of fdic insurance premiums . interest rate-sensitive assets  consist of spread-based assets and client cash invested in money market mutual funds . investment product fees  revenues earned on fee-based investment balances . investment product fees include fees earned on money market mutual funds , other mutual funds and through company programs such as advisordirect ® and amerivest ® . story_separator_special_tag significant judgment is required in making these estimates , and the actual cost of resolving a matter may ultimately differ materially from the amount accrued . valuation of guarantees we enter into guarantees in the ordinary course of business , primarily to meet the needs of our clients and to manage our asset-based revenues . we record a liability for the estimated fair value of the guarantee at its inception . if actual results differ significantly from these estimates , our results of operations could be materially affected . for further details regarding our guarantees , see the following sections under item 8 , financial statements and supplementary data  notes to consolidated financial statements : guarantees under note 15  commitments and contingencies and insured deposit account agreement under note 19  related party transactions . results of operations conditions in the u.s. equity markets significantly impact the volume of our clients ' trading activity . there is a direct correlation between the volume of our clients ' trading activity and our results of operations . we can not predict future trading volumes in the u.s. equity markets . if client trading activity increases , we expect that it would have a positive impact on our results of operations . if client trading activity declines , we expect that it would have a negative impact on our results of operations . changes in average balances , especially client margin , credit , insured deposit account and mutual fund balances , may significantly impact our results of operations . changes in interest rates also significantly impact our results of operations . we seek to mitigate interest rate risk by aligning the average duration of our interest-earning assets with that of our interest-bearing liabilities . we can not predict the direction of interest rates or the levels of client balances . if interest rates rise , we generally expect to earn a larger net interest spread . conversely , a falling interest rate environment generally would result in our earning a smaller net interest spread . financial performance metrics pre-tax income , net income , earnings per share and ebitda are key metrics we use in evaluating our financial performance . ebitda is a non-gaap financial measure . we consider ebitda to be an important measure of our financial performance and of our ability to generate cash flows to service debt , fund capital expenditures and fund other corporate investing and financing activities . ebitda is used as the denominator in the consolidated leverage ratio calculation for covenant purposes under our holding company 's senior revolving credit facility . ebitda eliminates the non-cash effect of tangible asset depreciation and amortization and intangible asset amortization . ebitda should be considered in addition to , rather than as a substitute for , pre-tax income , net income and cash flows from operating activities . 31 the following table sets forth ebitda in dollars and as a percentage of net revenues for the periods indicated , and provides reconciliations to net income , which is the most directly comparable gaap measure ( dollars in millions ) : replace_table_token_6_th our ebitda increased 17 % for fiscal 2013 compared to fiscal 2012 , primarily due to a 5 % increase in net revenues and $ 57 million of net gains on investments , while operating expenses were effectively unchanged . the increase in net revenues was primarily due to an 8 % increase in transaction-based revenues and a 3 % increase in asset-based revenues , partially offset by a 13 % decrease in other revenues . detailed analysis of our operating results is presented later in this discussion . our diluted earnings per share was $ 1.22 , $ 1.06 and $ 1.11 for fiscal years 2013 , 2012 and 2011 , respectively . higher ebitda was partially offset by a higher effective income tax rate for fiscal 2013 , resulting in a 15 % increase in net income compared to fiscal 2012. our effective income tax rate for fiscal 2012 was significantly lower than normal , primarily due to $ 19 million of favorable resolutions of state income tax matters and a $ 3 million benefit resulting from the reversal of a valuation allowance related to a capital loss carryover . these items favorably impacted diluted eps for fiscal 2012 by approximately four cents per share . based on our expectations for net revenues and expenses , we expect diluted earnings per share to range from $ 1.20 to $ 1.40 for fiscal year 2014. details regarding our fiscal year 2014 expectations for net revenues and expenses are presented later in this discussion . operating metrics our largest sources of revenues are asset-based revenues and transaction-based revenues . for fiscal 2013 , asset-based revenues and transaction-based revenues accounted for 55 % and 42 % of our net revenues , respectively . asset-based revenues consist of ( 1 ) net interest revenue , ( 2 ) insured deposit account fees and ( 3 ) investment product fees . the primary factors driving our asset-based revenues are average balances and average rates . average balances consist primarily of average client margin balances , average segregated cash balances , average client credit balances , average client insured deposit account balances , average fee-based investment balances and average securities borrowing and lending balances . average rates consist of the average interest rates and fees earned and paid on such balances . the primary factors driving our transaction-based revenues are total client trades and average commissions and transaction fees per trade . we also consider client account and client asset metrics , although we believe they are generally of less significance to our results of operations for any particular period than our metrics for asset-based and transaction-based revenues . asset-based revenue metrics we calculate the return on our interest-earning assets and our insured deposit account balances using a measure we refer to as net interest margin . net interest margin

