The commissioner would have a better basis for expressing an opinion on that than I would.
I don't see why the numbers make the difference on that issue. There are obvious circumstances where numbers do make a difference, but what's the difference if you have to make 70,000 orders as opposed to 700 recommendations? If you have a hybrid model where 700 recommendations are involved, why do you need an order model because 70,000 recommendations are involved? Why would there be a difference merely because of numbers?
You'd still have perhaps an even greater burden in the order-making model with 70,000 requests than you would with an order-making model with 700 requests. I would think the burden would be greater to use an order-making model than the hybrid model. That's my guess. The commissioner would know better than I.