[HN Gopher] SEC Chairman Says Banning Payment for Order Flow Is ...
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       SEC Chairman Says Banning Payment for Order Flow Is 'On the Table'
        
       Author : pcbro141
       Score  : 26 points
       Date   : 2021-08-30 19:30 UTC (3 hours ago)
        
 (HTM) web link (www.barrons.com)
 (TXT) w3m dump (www.barrons.com)
        
       | ab_testing wrote:
       | That would be bad for the retail investor. PFOF tightens the
       | spreads and increases speed of execution.
        
         | missedthecue wrote:
         | And subsidizes trading fees. Anyone else remember the days when
         | the "cheap" brokers like ScottTrade would charge you $10 every
         | time you bought or sold?
        
         | masonium wrote:
         | PFOF does not tighten "lit" spreads.
         | 
         | PFOF does offer price improvement, which can effectively
         | decrease the spread *for a particular marketable order".
         | However, PFOF drives volume away from the limit markets, which
         | determine the actual spread by which price improvement is
         | measured against. So, it's a bit of a shell game.
         | 
         | Concretely, at least 20% of all stock market volume is
         | internalized in PFOF-style firms (citadel, virtu, et. al). If
         | that volume were all on the lit exchanges instead, the spread
         | on those exchanges would be narrower on average.
        
           | gruez wrote:
           | >>PFOF tightens the spreads and increases speed of execution.
           | 
           | > PFOF does not tighten "lit" spreads.
           | 
           | But that's fine right? This whole debate is about whether
           | retail traders are being benefiting or losing (on net) from
           | this. For the retail trader, the price improvement they get
           | via PFOF is probably much better than the slightly better
           | spreads they'll get on lit exchanges if PFOF was banned.
        
             | jdsully wrote:
             | If that were true the market makers would be losing money
             | buying the order flow, and this conversation would be moot.
             | But instead these firms are quite profitable doing this.
             | It's a zero sum game so the money must come from somewhere.
        
               | gruez wrote:
               | >If that were true the market makers would be losing
               | money buying the order flow
               | 
               | No, because as other comments have mentioned, retail
               | orders are generally "non-toxic" and "uninformed", which
               | allows market makers to quote tighter spreads while still
               | maintaining profit.
        
               | jdsully wrote:
               | Are we then saying the loser is the institutional
               | traders? The money does not come from thin air.
        
               | gruez wrote:
               | Essentially, yes.
        
       | pcbro141 wrote:
       | Robinhood ($HOOD) down 8%
       | 
       | ~75-80% of Robinhood's revenue is Payment For Order Flow.
        
       | RosanaAnaDana wrote:
       | That would be great for the individual investor.
        
         | qeternity wrote:
         | PFOF (more broadly, HFT + maker taker) has tightened retail
         | spreads on both underlying AND options to levels previously
         | unfathomable. I don't get why people think retail are the ones
         | getting ripped off. Retail order flow is uninformed. It's
         | profitable for that reason, and nothing nefarious.
         | 
         | Institutional traders are the ones hurt by all of this. HFT
         | latency arbing every single sniff you put out, front running
         | every fill. PFOF has removed the uninformed order flow for
         | hedge funds to trade against so they're left trading against
         | each other, or getting their lunch eaten by the aforementioned
         | HFT.
        
           | slownews45 wrote:
           | Exactly. Basically they took the money being made by
           | institutions trading against individuals, and turned it into
           | a check back to the brokerages.
           | 
           | That said, I hate how much volume is handled off book with
           | these pricing approaches so not a huge fan of it?
        
             | qeternity wrote:
             | > off book
             | 
             | What do you mean?
        
               | slownews45 wrote:
               | Sorry. To be more specific.
               | 
               | Some of the orders can be internalized. Not sure how
               | often this occurs:
               | 
               | "The practice of internalization is prevalent in the
               | Nasdaq market where Nasdaq market makers, who often pay
               | for order flow or are sent order flow by an affiliate,
               | trade proprietarily against incoming customer orders.
               | NASD rules do not require Nasdaq dealers to expose their
               | internalized orders to competitors."
               | 
               | On the markets - since so much retail volume is off the
               | market, yes, the market maker has to price improve, but
               | it's against a less than full picture of the market for
               | thinly traded items.
        
               | gruez wrote:
               | probably meant "not being routed to open exchanges".
        
               | qeternity wrote:
               | Yeah, just wanted to be clear. Off book means something
               | else.
        
       | [deleted]
        
       | toomuchtodo wrote:
       | This is already banned in the UK, Canada, and Australia. I'm
       | unsure why its taken so long to ban in the US considering the
       | inherent conflicts of interest.
        
         | gruez wrote:
         | >This is already banned in the UK, Canada, and Australia
         | 
         | And they're paying $5-10 in trading commissions per trade. For
         | the typical retail trader whose order size is in the tens of
         | shares, it's unclear how they're being harmed more than they're
         | benefiting from it (from the free trading fees).
        
           | kwere wrote:
           | its the cost of investing, if that money is trouble for you
           | then you shouldnt invest/trade anyway
        
             | qeternity wrote:
             | No, it's not, as PFOF has proven.
        
             | gruez wrote:
             | Not sure about you, but given the choice between "$5/trade
             | but it's the best price" and "free trades you might be
             | losing a fraction of a cent per share", I'd take the
             | latter.
        
         | qeternity wrote:
         | > inherent conflicts of interest.
         | 
         | Which conflicts would those be?
        
           | [deleted]
        
           | ffggvv wrote:
           | Their duty should be to get the robinhood user the best
           | execution price for their trade. But they make no money from
           | the robinhood user, since there is no commission. Instead,
           | they get paid by the market maker whose interests are to get
           | the worst execution price possible for the robinhood user.
        
             | qeternity wrote:
             | By law, Reg NMS guarantees NBBO execution. Internalizers
             | are providing price improvement vs. dumping an order on a
             | lit exchange.
             | 
             | So by definition, the "worst price" would be routing via
             | SIP and execution against NBBO.
        
               | ffggvv wrote:
               | laws are one thing, that doesnt eliminate the conflict of
               | interest, it just regulates the ability to act on it.
        
               | qeternity wrote:
               | Uh, so if a conflict of interest exists (rife in all
               | markets) and laws prevent exploitation...what's the
               | issue?
        
               | toomuchtodo wrote:
               | The issue is PFOF is used by Robinhood to subsidize
               | unsophisticated investors trading more to their own
               | financial detriment.
               | 
               | https://www.bloomberg.com/opinion/articles/2021-08-30/esg
               | -ac... (Control-F "gamification")
               | 
               | https://www.sec.gov/news/press-release/2021-167 (SEC
               | Requests Information and Comment on Broker-Dealer and
               | Investment Adviser Digital Engagement Practices, Related
               | Tools and Methods, and Regulatory Considerations and
               | Potential Approaches; Information and Comments on
               | Investment Adviser Use of Technology)
               | 
               | https://www.sec.gov/rules/other/2021/34-92766.pdf
               | 
               | It's really no different then incentives and financial
               | mechanisms casinos use to get folks in the door. Or, as
               | the saying goes, "if you don't know who is the sucker at
               | the poker table, it's you."
        
               | qeternity wrote:
               | You're moving the goalposts.
               | 
               | Whether or not Robinhood gamifies trading, or encourages
               | gambling, has absolutely nothing to do with PFOF.
               | 
               | Ultimately people should be able to do with their money
               | as they please, include gambling it away on risky options
               | trades. Bad trading is naturally self correcting.
        
               | toomuchtodo wrote:
               | You asked me what the inherent conflict of interest is
               | top of thread. I stated it. The goal posts are firmly
               | where they started.
               | 
               | Robinhood is getting paid to bring a product (the user)
               | to market makers. If you're not paying for the product
               | you're the product, all the jazz.
               | 
               | > Ultimately people should be able to do with their money
               | as they please, include gambling it away on risky options
               | trades. Bad trading is naturally self correcting.
               | 
               | Agree to disagree. We regulate smoking, alcohol,
               | pharmaceuticals, gambling, and other behaviors that have
               | self harm. This is no different.
        
               | qeternity wrote:
               | Yes, I said that within the context of this thread, which
               | is PFOF...
               | 
               | If you're arguing that there's a conflict of interest
               | between Robinhood and its customers, then sure. But
               | that's got nothing to do with PFOF.
               | 
               | > Agree to disagree. We regulate smoking, alcohol,
               | pharmaceuticals, gambling, and other behaviors that have
               | self harm. This is no different.
               | 
               | Sure, I never said no regulation. You gotta stop with the
               | strawman attacks. We regulate these industries, as we
               | ought to do with finance, but we nonetheless allow people
               | to drink/smoke themselves to death or gamble themselves
               | into oblivion.
               | 
               | I'd rather live in a society where a small number people
               | do enormous bad to themselves, over one where the state
               | makes decisions for everyone.
        
               | ctvo wrote:
               | I'm ignorant of this space. Can you share how Robinhood
               | and others make money through order flow?
               | 
               | The semantics of it (an order has to receive the best
               | price at the time of execution for example) doesn't
               | capture the N ways a fund could make money here and still
               | be compliant.
               | 
               | Instead of worrying about the incorrect definitions used,
               | can you share how firms benefit from order flow instead?
        
               | qeternity wrote:
               | The exact mechanisms by which MMs monetize order flow is
               | the strictly guarded secret sauce. But largely it's
               | because retail order flow is uninformed, versus
               | institutional order flow (bank, hedge fund, etc) which
               | might be "toxic".
               | 
               | Here's an example with ridiculously huge spreads but just
               | to help illustrate the issue (in reality, the spreads are
               | fractions of a cent): let's say the market for AAPL
               | shares is 150 vs 151. A retail trader market sells 100
               | shares. Absent a dark pool or other internalizer, they
               | will end up hitting the 150 bid. A market maker knows
               | there is a buyer for AAPL shares and expects the 151
               | offer to trade. The market maker (MM) pays 10c to
               | Robinhood for the order, and buys the shares at 10c
               | better @ 150.10. The MM has paid 150.20 effectively
               | (151.10 + 0.10) when the next best buyer in the market
               | was 150.00. Why would they pay a 20c premium? Because of
               | the buyer I mentioned earlier that the MM believes will
               | buy their shares. The MM turns around and offers these
               | 100 shares for 150.90 (which is 10c better than the best
               | current offer of 151.00) and a hedge fund immediately
               | snaps those shares up.
               | 
               | So what's the net outcome? In this case, the trader has
               | gotten a better price, Robinhood has received revenue and
               | can offer their service for free, the MM has made a 70c
               | turn on the trade (150.90 - 150.20) and the hedge fund
               | buyer got a 10c better price than was available to them
               | in the first place.
               | 
               | Win, win, win, win.
               | 
               | (The real issue is that Robinhood forces market orders
               | which make retail traders consumer of liquidity and makes
               | all of this possible. But that's a different issue and
               | PFOF is not the bad guy.)
        
               | ctvo wrote:
               | Thank you for taking the time!
               | 
               | > The market maker (MM) pays 10c to Robinhood for the
               | order, and buys the shares at 10c better @ 150.10. The MM
               | has paid 150.20 effectively (151.10 + 0.10) when the next
               | best buyer in the market was 150.00.
               | 
               | Is this possible due to the technicalities in
               | regulations? Since they're paying a better price, it's OK
               | that they purchase the order from Robinhood and fill it
               | themself? The order didn't hit the "open market" or
               | whatever we'd consider it. It was filled before then, but
               | the best price on the open market was less than what was
               | filled for, regulators are happy.
               | 
               | Very interesting that the money is from retail customers
               | selling at bid, and makes sense.
               | 
               | If you'd like to share -- what's front running in this
               | scenario and how would MMs front run this, assuming it's
               | legal.
        
               | gruez wrote:
               | >Instead of worrying about the incorrect definitions
               | used, can you share how firms benefit from order flow
               | instead?
               | 
               | because there's a lower risk of being run over.
               | 
               | https://www.bloomberg.com/opinion/articles/2021-02-05/rob
               | inh...
               | 
               | The relevant 3 paragraphs start at "If the retail trades
               | are random..."
        
       | JumpCrisscross wrote:
       | > _He didn't say whether the agency has found instances where the
       | conflicts of interests resulted in harm to investors. SEC staff
       | is reviewing the practice and could come out with proposals in
       | the coming months._
       | 
       | This is the key question.
       | 
       | If we can't demonstrate harm, we have a theoretical problem
       | weighing against billions of dollars in commission savings. If we
       | _can_ show harm, the question would be of the lightest-touch way
       | to rectify that observed issue. Maybe it 's banning PFOF, but I
       | doubt it.
        
         | [deleted]
        
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