>Just wondering if occurs should be implemented the same way as in SQL Server?

Not the fanciest, but it does the job:

        ' Count the occurences of one string within another
        ' expC1 Character to look for
        ' expC2 String
        Public Function Occurs(ByVal tcCharacter As String, ByVal tcString As String) As Integer
            Dim lcString As String = ""
            Dim lnCount As Integer = 0
            Dim lnLocation As Integer = 0

            lcString = tcString

            Do
                lnLocation = lcString.IndexOf(tcCharacter, lnLocation)

                If lnLocation < 0 Then
                    Exit Do
                Else
                    lnCount = lnCount + 1
                    lnLocation = lnLocation + 1
                End If

            Loop While True

            Return lnCount
        End Function