BTE for what kind of hearing loss?

It was my understanding that BTE Hearing Aids were best for all kinds of 
hearing loss.

My brother-in-law says that when he got his aids a couple years ago from
the 
VA, he told them he would like to have BTE's and that he was told the BTE 
was not good for his type of hearing loss.  He is going on the 24th to get

another pair of aids and I have him enthused about my new Pho**** Exelia 
aids.  But I am at a loss as to what type of loss he may have that BTE
won't 
be satisfactory.

Any help from the pro's out there, or those with similar experiences would

be appreciated.

Thanks,

Jim