Can Brokers Have It All?

8/13/2019 Can Brokers Have It All?

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4 December 2013

Can Brokers Have it all?

On the Relation between Make Take

Fees & Limit Order Execution Quality.

by Robert Battalio, Shane Corwin, and Robert Jennings


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2

Average depth when al lare at the inside quote:

1stfive days of October 2012

Where are queues the shortest?

Where will an executed limit order generate the highest liquidity rebate?

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

NDAQ

$0.30$0.29

ARCA

$0.30$0.30

EDGX

$0.30$0.32

BZX

$0.29$0.29

NYSE

$0.23$0.21

BYX

- $0.02-$0.03

EDGA

- $0.04-$0.06

BSX

- $0.14- $0.18

Shares

Take Fee:Make Rebate:

Where is it cheapest to access displayed liquidity?


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3

When were fees explicitly introduced to

markets?

1997 Order Handling Rules.

The quotes displayed on computerized limit order books (think ECNs) were

incorporated into the public quotation system.

To attract liquidity onto their limit order books, ECNs and Nasdaq beganoffering liquidity rebates to reward market participants for placing non-

marketable orders on their limit order book.

These rebates were funded by charging incoming marketable orders a fee for

taking liquidity.

This is the traditional make/takemodel.


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4

The regulation of take fees.

Rule 610 of Regulation NMS (circa 2005) limits take fees to$0.003/share.

Why limit take fees?

Regulation NMS prohibits trading through the quotes of other markets.

Incentive to post bid price of $0.00 with a take fee of $1,000,000 per share.

Rule 610 is intended to preserve the integrity of the quote.

Why not simply post net prices on the real line???


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Who cares?

The Investment Company Institutes members, whomanaged over $11 trillion of assets and held 28% of

the value of publicly traded U.S. equity outstanding at

the end of 2009.

we are concerned that brokers may refrain from posting limit orders

on a particular exchange because it offers lower liquidity rebates than

other markets, even though that exchange offers the best possibil i ty of

an execution for those limit orders. Practices such as these, in turn,

may ultimately harm investors because their limit orders may not beexecuted. At the same time, it is unclear what benefits liquidity rebates

provide to investors. (emphasis added)


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What is the Investment Company Institute

saying?

1. Brokers may be more concerned about harvesting rebates than

they are about obtaining best execution for customer orders.

The classical principal/agent problem.

2. This type of order routing results in inferior limit order

execution quality.

3. Competition and transparency cannot fix this problem.


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1. Would brokers really do this?

Chris Nagy, Wall Streets most sophisticated order sender

Traders Magazine.

The group Nagy heads endowed Ameritrade with the ability

to separate marketable and non-marketable order flow.

It sends its market orders to wholesalers and receives payments.

it began sending its limit orders to exchangesto take advantage of their

rebatesfrom maker-taker pricing.

In splitting its order flow, Ameritrade could improve its revenues by taking

advantage of maker-taker pricing at the exchanges and still get paid for sending

order flow to the wholesalers.


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2. Are standing limit orders harmed (1 of 4)?

Suppose there are two order books at the National Best Bid (NBB)

for Pudgys Chicken common stock.

EDGX EDGANBB $10.24 $10.24

Make Rebate:

Take Fee:

+ $0.0023 - $0.0004

+ $0.0029 - $0.0005

Does the order routing decision matter?


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Are standing limit orders harmed (2 of 4)?

Scenario 1:

Negative earnings news is announced. Market sell orders push

the market price for PudgysChicken down to $9.99 bid and

$10.01 offered.

Both limit buy orders execute.

Both limit buy orders have negative realized spreads (five minute alphas).

In this situation, execution happens regardless of where the order is sent

you might as well receive a high rebate.


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Scenario 2:

A fee-sensitive investor routes a marketable sell order to EDGA

and trades with the standing limit order. Subsequently, buying

pressure pushes the market for PudgysChicken to $10.49 bid

and $10.51 offered.

Only one limit buy order executes.

The executed limit order generates a positive realized spread.

In this situation, the limit order resting on the venue with the higherliquidity rebate (and higher take fee) misses out on a profitable trading

opportunity.


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Scenario 3:

A marketable sell order is routed to EDGX instead of EDGAbecause of faster connections and/or the expectation of greater non-

displayed liquidity (e.g., price/depth improvement). Subsequently,buying pressure pushes the market for PudgysChicken to $10.49 bid

and $10.51 offered.

Only one limit order executes.

The executed limit order generates a positive realized spread.

In this situation, the limit order resting on the venue with the higher

liquidity rebate (and higher take fee) received a favorable execution and

received the liquidity rebate!


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3. Why cant Adam Smith fix this?

Brokers only get commissions when limit orders execute. Why

wouldnt brokers seek high fill rates rather than high rebates?

Big agency problem - Angel, Harris, and Spatt (2010).

Hard for investors to evaluate limit order execution quality.

Easy for investors to shop based on commissions.

Brokers that seek to maximize order rebates can offer the lowest commissions.

Investors cannot see that paying a higher commission might actually make

them better off.


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Our contribution

13


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What do BCJ do? (2 of 3)

Limit order execution quality metrics for orders

Fill rates & queue lengthsOn which venue are limit orders executed most

frequently?

HorseracesFor identical orders routed to multiple venues, we examine where

orders are executed first.

Conditional on an execution

Execution speed - Where are limit orders executed more quickly?

Realized spreads & good fill ratiosWhich venue offers limit order

executions the largest five minute alpha? On which venue are adverse

selection costs the greatest?


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What do BCJ do? (3 of 3)

We use proprietary limit order data and the NYSEs TAQ data from

October and November 2012 to address these issues.

Overall, we present strong evidence that venues with high take fees

(liquidity rebates) offer inferior limit order execution quality.

This suggests brokers cannot have it all.

Brokers must either choose to maximize liquidity rebates or to

maximize limit order execution quality.


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Literature review

17


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Literature Review (as it pertains to our paper)

Academic (publicly available data)

Foucault and Menkveld (2008) & Cardella, Cao and Kalcheva (2013)

Fee schedules are a primary determinant of where marketable

orders are routed.

Practitioner (proprietary data)

Sofianos and Yousefi (2010), Sofianos, Xiang, and Yousefi (2010), &

Bacidore, Otero and Vasa (2011)

Evidence suggests routing decisions (influenced by fee schedules)

affects execution quality.


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Broker order routing in 4Q12.

19


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Order Routing (1 of 6) SEC rule 606 requires brokers to reveal on a quarterlybasis

the destinations to which they route non-directed orders and

whether they receive compensation for their routing choices.

Any venue receiving less than 5% of the brokers orders does not have

to be revealed on the brokers 606 report.

Thus, percentages need not sum to 100.

We collect 4Q2012 Rule 606 reports for ten national brokerages

appearing in either Barrons or Smart Moneys 2012 Broker Surveys

from broker websites.

We present results for routing in NYSE-listed securities.


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Order Routing (2 of 6)

Five brokers route 100% of their order flow to

purchasers of order flow: Schwab, Morgan Stanley,Just2Trade, Edward Jones, and LowTrade.

Limit orders routed to any of these brokers have an opportunity to

interact with both the brokers and the purchasers marketable orderflow. Manning rules are intact.

Purchasers pay brokers less for order flow they cannot interact with.

Thus, this type of order routing does not, on the surface, appear to

be consistent with the objective of maximizing order flow

payments.


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22

Venue

Make/Take

Order

Mix Ameritrade E*Trade Fidelity ScottTrade

EDGX

$0.32/-$0.30

% Mkt 0% 0% 0% 0%

% Lmt 49% 46% 28% 28%

Lava

$0.27/-$0.28

% Mkt 0% 0% 0% 0%

% Lmt 0% 0% 0% 51%

Purchasers

$0.00/


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Venue

Take Fee

Order

Mix

Interactive

Brokers

Nasdaq

$0.30% Lmt 7%

NYSEs Arca Exchange

$0.30% Lmt 23%

Bats Z Exchange

$0.29 % Lmt 14%

NYSE (vintage)

$0.23% Lmt 47%

Uses a smart order router

and passes fees/rebates

onto customers

Traditional venue with lowest take fee

Why no inverted

routing?


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Retail Limit Orders Institutional Limit Orders

Direct Edge 30.45% 9.91%

Nasdaq 0.00% 11.28%

BATS 0.00% 15.02%

NYSE 0.00% 22.49%

Citadel (wholesaler) 9.72% 0.08%

Goldman 3.37% 1.71%

NFS (wholesaler) 19.19% 27.04%

Knight (wholesaler) 21.36% 1.12%UBS (wholesaler) 5.72 0.75%

Two Sigma (wholesaler) 2.79% 0.00%

24

Fidelitys non-directed limit order routing in 3Q2013


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Analysis of proprietary limit orderdata.

26


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Data

We obtain limit order data from a major broker-dealers smart

order routing system for October and November 2012.

The orders in the sample are from customers, primarily

institutional investors.

Orders included are those routed through the broker-dealers

algorithmic trading system and orders entered directly by

customers.

25thpercentile and median order size is 100 shares. 75th

percentile order size is 300 shares. The median (75thpercentile)

order displays 0 (100) shares.


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Where are orders sent?

28Unfortunately, not many orders are routed to the inverted venues.

VenueTake Fee

Min/Max

Displayed Order

Make Rebate

Hidden Order

Make Rebate

% of Displayed

Orders

(N=10,392,317)

% of Hidden

Orders

(N=17,829,197)

EDGX $0.29/$0.30 +$0.23/+$0.32 +$0.23 29.72% 31.97%

NDAQ $0.30/$0.30 +$0.20/+$0.29 +$0.10 23.84% 39.76%

ARCA $0.30/$0.30 +$0.21/+$0.30 +$0.21 12.61% 11.36%

BZX $0.29/$0.29 -$0.25/+$0.29 -$0.10 5.26% 2.15%

NYSE $0.23/$0.23 +$0.15/+$0.21 +$0.15 26.72% 14.46%

EDGA -$0.04/-$0.04 -$0.06/-$0.05 -$0.06 0.20% 0.00%

BSX -$0.14/-$0.14 -$0.18/-$0.15 -$0.18 1.65% 0.30%


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Order outcomes

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Fill Status # of Orders Rejected Replaced Cancelled One Fill Expired

No Fill 17,455,297 1,681 117,895 15,853,841 n.a. 1,481,880

Complete 10,231,469 0 8 53,083 7,964,586 n.a.

Partial Fill 534,748 1 107 524,757 349,482 9,883


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Order aggressiveness

30

Limit Order Type Buy Orders Sell Orders

Behind-the-quote 14.90% 12.32%

At-the-Quote 30.74% 29.76%

Inside-the-Quote 5.48% 5.24%

Marketable 0.65% 1.04%

Limit Order TypeDisplay Choice

Hidden Partially or Fully Displayed

Behind-the-quote 32.21% 18.56%

At-the-Quote 58.84% 63.34%

Inside-the-Quote 7.19% 16.77%

Marketable 1.88% 1.38%


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Probit analysis of limit order fill rates (1 of 2)

Fill = 0+ 1Sell + 2Short Sell + 3Display + 4Moneyness + 5Trading Intensity +

6Price + 7Volatility + 8Seconds from Mid-day + 9Mean Response Time +10Order Size + 11Take Fee + 12(Display)(Take Fee) +

Caveats:

Control variables are created within sample from actual orders. Wecan/will do a much better job of this in next version of paper. We dont

think things will change.

Hypothesis: The probability that a displayed limit order fills is decreasing

in an exchanges take fee.

(11+ 12) < 0

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Probit analysis of limit order fill rates (2 of 2)

Results:

A limit order is more likely to execute if i t is

displayed, small, aggressively priced, and if it is placed on a

venue with faster connections to our broker.

in a less volatile, less active stocks. Endogeneity???

displayed on a venue with a lower take fee.


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OLS analysis of limit order time-to-execution (1 of 2)

Speed = 0+ 1Sell + 2Short Sell + 3Display + 4Moneyness + 5Trading Intensity +

6Price + 7Volatility + 8Seconds from Mid-day + 9Mean Response Time +10Order Size + 11Take Fee + 12(Display)(Take Fee) +

Caveats:

Control variables are created within sample from actual orders. Wecan/will do a much better job of this in next version of paper. We dont

think things will change.

Hypothesis: The time-to-execution for displayed venues is increasing in the

size of the take fee.

(11+ 12) < 0

34


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OLS analysis of limit order time-to-execution (2 of 2)

Results:

Time-to-execution is shorter for limit orders that are

displayed, small, aggressively priced, and if it is placed on a

venue with faster connections to our broker.

in more volatile, more active stocks.

routed to venues with lower take fees.


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Horseraces (1 of 2)

We identify order-pairs that have the same stock symbol, order

date, order side (buy or sell), limit price, order time (to withinone millisecond), but different destination venues.

By construction, these paired orders control for stock characteristics

and market conditions.

For each pair of identical orders routed to different venues, we

conduct a horserace to determine which venue (if either) seems

to perform better.


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EDGX vs. the NYSE (1 of 3)

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All Order Pairs # of Order

Pairs

% Both

Fill

Difference in

Time to 1stFill1stVenue

(take fee)

2ndVenue

(take fee)

EDGX

($0.30)

NYSE

($0.23)258 14.34 1.01

NYSE

($0.23)

EDGX

($0.30)461 9.33 57.91


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Order Pair # of Order

Pairs

% 1stVenue

Trades First

% 2ndVenue

Trades First% Tie1stVenue

(take fee)

2ndVenue

(take fee)

EDGX

($0.30)

NYSE

($0.23)

258 10.08 82.56 7.36

NYSE

($0.23)

EDGX

($0.30)461 91.32 3.47 5.21

Takeaway:Roughly 5% of the horseraces end in a tie (it didntmatter where the order was routed). When it did matter, the

NYSE offered the first fill muchmore frequently.


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Takeaway:A higher percentage of executions produce positiverealized spreads on the NYSE. However, the median realized

spread is positive on both the NYSE and on EDGX.

Order Pair Good Fill Ratio

1stVenue

(take fee)

2ndVenue

(take fee)1stVenue 2ndVenue

EDGX

($0.30)

NYSE

($0.23)51.79 58.78

NYSE

($0.23)

EDGX

($0.30)65.72 55.36


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Horseraces involving all orders that do not end in ties.

41

23.59%

68.35%64.02%

54.45%

60.01%

68.78%

93.79%

99.74%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

BZX vs ARCAFee Diff = $0.01

N = 1,433

BZX vs NDAQFee Diff = $0.01

N = 9,811

BZX vs EDGXFee Diff = $0.01

N = 24,309

NYSE vs BZXFee Diff = $0.06

N = 2,637

NYSE vs ARCAFee Diff = $0.07

N = 550

NYSE vs NDAQFee Diff = $0.07

N = 51,240

NYSE vs EDGXFee Diff = $0.07

N = 676

BSX vs NDAQFee Diff = $0.44

N = 3,128

% of horseraces wonby low fee venue


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Horseraces involving all displayedorders that do not

end in ties.

42

85.30%81.04%

71.95%

51.27%

65.77%69.88%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%


N = 170


N = 327


N = 2,934


N = 310


N = 149


N = 1,604

% of horseraces wonby low fee venue


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What does it mean to win a set of

horseraces?

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Horseraces involving all orders that do not end in ties.

44

-0.39%

2.15%

0.26%

2.92% 2.73% 2.72%

9.15%

11.03%

-2%

0%

2%

4%

6%

8%

10%

12%


N = 1,433


N = 9,811


N = 24,309


N = 2,637


N = 550


N = 51,240

NYSE vs EDGXFee Diff = $0.07

N = 676

BSX vs NDAQFee Diff = $0.44

N = 3,128

Difference in good fill ratios.

Difference is positive if low fee venue

has a higher good fill ratio

Summary of results obtained from proprietary


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Summary of results obtained from proprietary

data. (1 of 2)

Univariate statistics suggest a negative relation between take fees and fill ratesand between take fees and realized spreads.

Multivariate probit analysis reveals that for displayed orders, there is a negative

relationship between take fees and limit order fill rates.

OLS regression analysis confirms that limit orders resting on venues with high

take fees require more time to fill than those on venues with lower take fees.

Our examination of identical order pairs simultaneously routed to different

venues under identicalmarket conditions reveals that for take fee differencesexceeding $0.0001 per share, the lower take fee venue has higher measured

limit order execution quality.

Summary of results obtained from


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Summary of results obtained from

proprietary data. (2 of 2)

Our results suggest the decision to route the bulk of ones limit

orders to a singlevenueoffering the highest liquidity rebate is

inconsistent with a brokers fiduciary responsibility to obtain

best execution.

Shortcomings of our analysis of proprietary


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Shortcomings of our analysis of proprietary

data.

The executed limit orders in our dataset are from a singlebroker and theycomprise about 1.5% of average daily volume.

Our data do not span the thirteen U.S. stock exchanges that utilize make-

take or inverted make-take fee schedules.

Specifically, our data provider uses inverted venues somewhat

sparingly.

Our proprietary data do not allow us to examine the types of

stocks/situations in which the routing of limit orders to venues withrelatively high take fees does not harm limit order execution quality.


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Using the NYSE TAQ database to makeinferences regarding across-venue limit

order execution quality.

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Wh t b d ith TAQ? (1 f 3)


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What can be done with TAQ? (1 of 3)

TAQ data can be used to determine whether fees influence

where marketable orders (as evidenced by trades) execute whenmultiple venues have the best posted quote.

Based on the analysis in the prior section, we expect that venues with

lower or negative take fees receive a larger share of marketable orders

than venues with high take fees when all venues display the best quote.

Unless the three venues charging take fees of $0.30 per hundred always

have the shortest queues when they are at the best quote or the market

alwaysexhausts the depth at posted quotes, such a finding would suggest

that brokers seeking to obtain best execution for customer limit orders

should not route 100% of their limit orders to a single high take fee venue.



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TAQ data can be used to compute the realized spreads of

executions that take place at the quoted price when each of therelevant trading venues is posting the best quote.

Assuming these quotes are set by limit orders, we can examine

the association between take fees (make rebates) and the

execution quality of executedlimit orders.

Do limit orders resting on venues with higher take fees face

higher adverse selection costs because they tend to be the last

to trade at a price?



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We can also examine the extent to which across-venue

differences in limit order execution quality dissipate when

fees/rebates are incorporated into realized spreads.

We might expect the all in cost of limit order trading (e.g., the

implementation shortfall) to equilibrate across venues.

Investors must chase the market to ultimately satisfy their trading

interests when limit orders are unfilled. Implementation shortfall

captures this cost.

This does not imply that fee-adjusted realized spreads should

equilibrate across venues.

How restrictive is our focus on trades executed at


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How restrictive is our focus on trades executed at

the quote when all venues are at the quote?

12.25% of all non-sweep trades in NYSE-listed securities occur at thequote when each of the relevant trading venues is at the inside quote.

The median NYSE stock has 0.24% of its non-sweep trades executed at the

quote when all are at the quote.

Ford is the stock with the highest percentage, 52.23%, of non-sweep trades

executed at the quote when all are at the quote. Ford traded between $9.71

and $10.16 during the 1stweek of October.

Over 99% of the trades executed at the quote when all venues are at the

inside quote occur when the width of the NBBO is equal to $0.01.

M k t h f t d i NYSE li t d iti


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Market share of trades in NYSE-listed securities.(No sweep trades)

0.00%

2.00%

4.00%

6.00%

8.00%

10.00%

12.00%

14.00%

16.00%

18.00%

NDAQ$0.30

ARCA

$0.30

EDGX

$0.30

BZX

$0.29

NYSE

$0.23

BYX

-$0.02

EDGA

-$0.04

BSX

-$0.14

Unconditional All at inside quote & trade at inside quoteThe NYSE is always at the

inside quoteothers are not.

Internalization?

A d th h ll t th i id t


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Average depth when all are at the inside quote

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

NDAQ

$0.30

ARCA

$0.30

EDGX

$0.30

BZX

$0.29

NYSE

$0.23

BYX-$0.02

EDGA-$0.04

BSX-$0.14

I te et ti


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Interpretation

On average, inverted venues have shorter queues and are at

least as likely to receive marketable orders as the traditional

venues.

Hard to rationalize routing all/mostof your limit orders to a

single traditional venue offering the highest liquidity rebate

(charging the highest take fee) if fees/rebates are not passed

through to investors.

55

Unconditional realized spreads in NYSE-listed


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Unconditionalrealized spreads in NYSE-listed

securities. (No sweep trades)

-3

-2

-1

01

2

3

4

5

EDGX

$0.30

ARCA

$0.30

NDAQ

$0.30

BZX

$0.29

NYSE

$0.23

BYX

-$0.02

EDGA

-$0.04

BSX

-$0.14

Avg. realized spread (bps.)

Realized spreads for trades at the quote when all are


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Realized spreads for trades at the quote when all are

at the quotein NYSE-listed securities. (No sweep trades)

-4

-2

0

2

4

6

8

EDGX

$0.30

ARCA

$0.30

NDAQ

$0.30

BZX

$0.29

NYSE

$0.2

3

BYX

-$0.02

EDGA

-$0

.04

BSX

-$0.14

Avg. realized spread (bps.) Avg. realized spread when all are at inside (bps.)

Order flow becomes

more toxic!

Order flow becomesless toxic!


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Interpretation


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Interpretation

On average, at-the-quote limit orders receive more favorable

executions on inverted venues (and the NYSE).

At-the-quote limit orders resting on inverted venues face lower

adverse selection costs.

Indeed, over half of the executed at-the-quote limit orders on the

inverted venues and the NYSE have positive realized spreads!

59

Unconditional conditional and adjusted realized


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60

Unconditional, conditional, and adjusted realized

spreads for trades in NYSE-listed securities. (No sweep trades)

-4

-2

0

2

4

6

8

EDGX

$0.30

ARCA

$0.30

NDAQ$0.30

BZX

$0.29

NYSE

$0.23

BYX

-$0.02

EDGA

-$0.04

BSX

-$0.14


Avg. realized spread when all are at inside (bps.)

Adjusted realized spreads when all are at the inside (bps.)



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-4

-2

0

2

4

6

8

EDGX

$0.30

ARCA

$0.30

NDAQ$0.30

BZX

$0.29

NYSE

$0.23

BYX

-$0.02

EDGA

-$0.04

BSX

-$0.14



47%

IBs limit order routing

7% 14%22%



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-4

-2

0

2

4

6

8

EDGX

$0.30

ARCA

$0.30

NDAQ$0.30

BZX

$0.29

NYSE

$0.23

BYX

-$0.02

EDGA

-$0.04

BSX

-$0.14



22%

Fidelitys institutional limit

order routing

11% 15%

10%

Interpretation


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Interpretation Conditional on an execution, investors who are responsible for the fees/rebates that

their trades generate earn the highest adjusted realized spreads on the NYSE, a

traditional venue.

Apparently, the liquidity on the inverted venues does not absorb all of the good

fills.

Relative to the NYSE, for executed limit orders, thebenefit of gaining net pricepriority on the BSE is, on average, outweighed by the differential in make rebates

(which is at least $0.003/share).

Is why the smart routers used by brokers that pass on fees/rebates do not use the

inverted venues that frequently?

Table VIII reveals the inverted venues spend much less time at the inside quote

than traditional venues.

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Conclusions (1 of 2)


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Conclusions (1 of 2) Several large, national brokerage are making order routing decisions that appear to

be consistent with the goal of maximizing order flow rebates.

Each of these brokers routes limit orders either to a market maker or to a single

traditional venue that pays the highest rebates.

Proprietary data suggests this type of order routing results in lower fill rates

and increased adverse selection costs.

We find similar results using TAQ data.

We have identified situations in which expected fill rates are higher on inverted

venues

Adverse selection costs are highest on the traditional venues.

65



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Our evidence suggests brokers who do not pass fees/rebates

onto customers cannot have it all.

Maximizing liquidity rebates on executed orders is inconsistent

with obtaining best execution for non-marketable limit orders.

Can Brokers Have It All?

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Transcript of Can Brokers Have It All?