Read up on Rules 610 and 611 of Regulation NMS. All trades unless expressly reported as exempt are required to be filled at the NBBO.
When we process and analyze the daily message streams on average 3% of all trades are reported outside the NBBO. Below is a compilation for December 31 2012.
Exchange Trades Outside NBBO Rate
Nasdaq Exchange (NQEX) 4,513,474 43,975 1.0%
New York Stock Exchange (NYSE) 1,915,599 14,141 0.7%
American Stock Exchange (AMEX) 43,507 318 0.7%
Chicago Board Options Exchange (CBOE) 125,989 438 0.3%
NYSE ARCA (ARCA) 3,455,116 37,977 1.1%
National Stock Exchange (Cincinnati) (CINC) 51,340 1,055 2.1%
Philidelphia Stock Exchange (PHIL) 167,157 927 0.6%
Boston Stock/Options Exchange (BOST) 948,215 3,817 0.4%
Nasdaq Bulletin Board (NQBB) 1,220 - 0.0%
Chicago Stock Exchange (CHIC) 3,181 44 1.4%
NSX Trade Reporting Facility (NQNX) 4,625,533 394,051 8.5%
NYSE Trade Reporting Facility (NTRF) 892,538 103,632 11.6%
BATS Trading (BATS) 2,859,565 31,688 1.1%
BATS Trading (BATY) 1,192,579 4,836 0.4%
Direct Edge (EDGE) 722,338 5,174 0.7%
Direct Edge (EDGX) 1,833,902 25,328 1.4%
Total across 16 Market Centers 23,351,253 667,401 2.9%
When you analyze the BAT Stream you can clearly see market centers jumping the gun and filling orders at the next NBBO before the quotes hit the NMS.
The pattern is so obvious: a trade reports outside of the instant NMS NBBO and the next NBBO Top of the book change reflects the already filled order price. Some of the price jumps are significant and have the same effect as sweeping the order book without the capital risk.
Our regulators use an enhanced electronic blue sheet system to investigate trades. They basically ask the SRO foxes for an inventory of hens...
This blue sheet data only requires trade dates and does not contain execution time stamps. FINRA has made changes to the Blue Sheet reporting regulations in 2011 requiring second timestamps. Implementation has been delayed twice and is scheduled to go in effect May of 2013. No doubt a huge industry push back is being lobbied to not report timestamps by the SROs.
Unfortunately our regulators do not have the tools, data or technology to enforce basic trade reporting rules thwarting fair play.
When we process and analyze the daily message streams on average 3% of all trades are reported outside the NBBO. Below is a compilation for December 31 2012.
Exchange Trades Outside NBBO Rate
Nasdaq Exchange (NQEX) 4,513,474 43,975 1.0%
New York Stock Exchange (NYSE) 1,915,599 14,141 0.7%
American Stock Exchange (AMEX) 43,507 318 0.7%
Chicago Board Options Exchange (CBOE) 125,989 438 0.3%
NYSE ARCA (ARCA) 3,455,116 37,977 1.1%
National Stock Exchange (Cincinnati) (CINC) 51,340 1,055 2.1%
Philidelphia Stock Exchange (PHIL) 167,157 927 0.6%
Boston Stock/Options Exchange (BOST) 948,215 3,817 0.4%
Nasdaq Bulletin Board (NQBB) 1,220 - 0.0%
Chicago Stock Exchange (CHIC) 3,181 44 1.4%
NSX Trade Reporting Facility (NQNX) 4,625,533 394,051 8.5%
NYSE Trade Reporting Facility (NTRF) 892,538 103,632 11.6%
BATS Trading (BATS) 2,859,565 31,688 1.1%
BATS Trading (BATY) 1,192,579 4,836 0.4%
Direct Edge (EDGE) 722,338 5,174 0.7%
Direct Edge (EDGX) 1,833,902 25,328 1.4%
Total across 16 Market Centers 23,351,253 667,401 2.9%
When you analyze the BAT Stream you can clearly see market centers jumping the gun and filling orders at the next NBBO before the quotes hit the NMS.
The pattern is so obvious: a trade reports outside of the instant NMS NBBO and the next NBBO Top of the book change reflects the already filled order price. Some of the price jumps are significant and have the same effect as sweeping the order book without the capital risk.
Our regulators use an enhanced electronic blue sheet system to investigate trades. They basically ask the SRO foxes for an inventory of hens...
This blue sheet data only requires trade dates and does not contain execution time stamps. FINRA has made changes to the Blue Sheet reporting regulations in 2011 requiring second timestamps. Implementation has been delayed twice and is scheduled to go in effect May of 2013. No doubt a huge industry push back is being lobbied to not report timestamps by the SROs.
Unfortunately our regulators do not have the tools, data or technology to enforce basic trade reporting rules thwarting fair play.