Mr. Plumeri said his firm has received no indications from investigators that it would be subject to the allegations made against those other brokers.

"We have not put up a reserve," said Mr. Plumeri in response to an analyst's question during a conference call to discuss the broker's year-end results. "We found no reason to put up a reserve. We haven't had discussions with the attorney general that would suggest that we should put up a reserve."

He did note, however, that there was the possibility someone within the organization may have acted improperly, outside of the knowledge of Willis, but insisted that there was no institutional misconduct.

On Wednesday, during the announcement of its year-end results, Aon said it set up a $50 million reserve toward a settlement with the New York attorney general's office and other investigators probing contingency fee abuses.

Late last year, MMC said it would set up a $250 million fund for such a settlement. On Jan. 31, MMC announced a $850 million settlement with New York to pay clients whose accounts were involved in the payment of contingency fees to Marsh, MMC's insurance brokerage subsidiary.

Willis was the first to ban acceptance of all insurer contingency fees after Mr. Spitzer announced a suit against MMC alleging bid-rigging, price-fixing, and steering of insurance contracts in exchange for profitable volume-driven contingency fees from insurers.

Mr. Plumeri said the firm recorded $71 million in contingent fees in 2004, a revenue number it must now work to replace through a combination of fees, new business and commissions.

In the fourth quarter, Willis reported a drop in net income of less than 9 percent, or $10 million, going from $118 million, or 69 cents a share in 2003, to $108 million, or 65 cents a share. Revenues increased 2 percent, or $11 million, going from $577 million to $588 million.

For the year, net income increased more than 3 percent, or $13 million, going from $414 million, or $2.45 a share, to $427 million, or $2.54 a share. Revenues increased less than 10 percent, or $199 million, going from less than $2.08 billion to less than $2.28 billion.

Mr. Plumeri noted that Willis' earnings were affected by the loss of contingent commissions in the fourth quarter, which dropped from $39 million in 2003 to $25 million. He added that the firm returned some fees to insurers to keep with its stated position not to accept them.

The weak dollar reduced foreign revenues by 4 percent, Willis said, and the effects from the softening market translated into only 3 percent organic growth for the firm.

The investigation into contingent commissions and compliance with new federal Sarbanes-Oxley Act disclosure requirements cost Willis an additional $10 million, $1 million of which was related to Sarbanes-Oxley alone, executives said.