Dave Lauer Profile picture
Jan 26 7 tweets 3 min read
I wrote something about Payment For Order Flow, Price Improvement and high-speed speculators.

tldr; PFOF brokers are not getting best execution, and there's some data to prove it.

urvin.finance/blog/how-is-th…
There are several things going on here. First, the NBBO is a flawed benchmark, one that is being damaged & widened by the very practice of PFOF/internalization.

It’s like marking up a TV by 25% & then giving your customers 1% off and telling them they’re saving a ton of money.
Second, there are often better prices out in the market that the internalizers know about, and I show a trade that looks very much like front-running, albeit at millisecond timescales.
Finally, we explored off-exchange, sub-penny trades and found that by far, many trades only receive the bare minimum 1 mil of price improvement. This looks a lot like juicing the stats to claim that a high % of trades get price improvement despite it being de minimis.
Markets are being harmed by this practice, which is increasing the cost to trade for everyone, including institutional asset managers. Retail is not getting the best possible price through this closed, anti-competitive system with power concentrated in few firms.
In the end, I just completely agree with Citadel. "The practice of PFOF ... should be banned ... Internalization without meaningful price improvement reduces competition, limits price discovery, leads to market fragmentation, and should be banned."
Check out the post, let me know what you think, and if you're interested in supporting our efforts @UrvinTerminal sign up for our beta wait list here:
urvin.finance

You'll be hearing more from us in 2 days - something about that date (Jan 28) rings a bell, right?

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More from @dlauer

Dec 28, 2021
2022 will be a monumental year in market structure, w/big proposals coming from SEC on off-exchange trading and PFOF. Part of what we will do @UrvinTerminal is make sure that retail has a well-informed voice in this debate. Support our efforts here:
wefunder.com/urvinfinance/
@UrvinTerminal I believe in leveling the playing field - getting retail investors access to the same high quality data and tools that the professionals have.

I believe in truly democratizing information, data and access - not turning retail into a product to be sold to high-speed speculators.
I believe that you can align incentives so that everyone wins, while taking on the biggest and most powerful incumbents on Wall St.

I believe we can change the system when we work together, point out corruption, and build a movement so big, it can't be ignored!
Read 8 tweets
Nov 2, 2021
Ok, it’s time for some game theory. For real! Let’s talk about the conflicts-of-interest at the heart of nearly all equity routing today – rebates & payments. These inducements (that’s an important word) influence how brokers route orders, for retail and institutions.
First of all, for retail, I think everyone understands that PFOF involves market makers paying brokers to send retail orders to them. Most of the time these are marketable orders. Limit orders are often sent to exchanges.
For example, here is Fidelity’s order routing showing marketable orders going mostly to Citadel and Virtu, and non-marketable orders going to NYSE and Nasdaq. Non-marketable limit orders receive a rebate when they are sent to an exchange
Read 15 tweets
Oct 26, 2021
Remember in February when Thomas Peterffy said:
"We have come dangerously close to the collapse of the entire system."

I just had a very stimulating discussion on the nature of systemic risk, market structure and leverage / shorting.

How is it even possible that GME could've brought something like this about?

Can you imagine if GME was responsible for the entire market grinding to a halt?
What's even crazier? Nothing has changed, 10 months later. We are 10 months after an event that could have brought the entire US market down, and nothing has changed. Nothing has been done. There is systemic risk in market structure that is not being addressed.
Read 11 tweets
Oct 12, 2021
This is the story all the current internalizer apologists want you to believe - "retail has never had it better." They neglect to mention the costs this has imposed on pension plans and mutual funds, or that the measurement is flawed because of artificially wider spreads.
Segmenting retail order flow harms markets, and widens spreads. Then those who champion this segmentation measure so-called "price improvement" against a wider spread, and claim "retail has never had it better." It's disingenuous, & of course those making the argument know that.
But Virtu, Citadel and the retail brokers are simply making too much money so they're desperate to maintain the system. They will fight the SEC tooth and nail on this, in order to preserve their annual bonuses.
Read 4 tweets
Sep 17, 2021
While this soundbite sounds good, it's not accurate. Using standard measures of market concentration, you can EASILY see that off-exchange trading is highly concentrated, and for large retail brokers it fits the DOJ definition for anti-trust enforcement.
The Herfindahl Index (HHI) is a standard measure of corporate concentration. Total OTC trading in July 2021 showed an index of nearly 2,000, but that doesn't tell the real story. Looking just at HOOD's 606, their HHI ranges from 2,500 (S&P 500) to over 3,000 for options.
This is the literal definition of corporate concentration, and it results in worse outcomes for everyone involved (except for the wholesalers and HOOD executives).
Read 5 tweets
Sep 15, 2021
You know what's terrible and sad? Earlier this year, Facebook's head of AI @ylecun told me, absurdly, that Facebook's "AI" "filter[s] things like ... bullying." All while he knew this to be untrue.
@ylecun Instead of responding rashly on Twitter, I wrote an extensively researched piece exploring Facebook's issues, including issues around harassment and bullying for the Journal of AI and Ethics:
link.springer.com/article/10.100…
@ylecun Facebook's problems are not technology problems, as the WSJ article so clearly establishes. It's problems are that it is a deeply unethical organization from top to bottom, and its business model enforces and supports that.
Read 7 tweets

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