It can apply to any broker who does volume above the minimum threshold.
It does seem interesting that IB already seems to know that it will fail and has instituted the fees 2 months before the fees will be charged to them.
The idea of the test period was to give a heads up to clearing brokers as to whether they would get charged and to perhaps give them a chance to calm their prop operations or calm their high frequency/tuning clients.
Seems odd that IB knows it will fail and will continue to fail and it seems even odder, that they would institute the charges on the retail side. While I feared when I saw the new Globex messaging policy that CME was going the way of CBOE to protect its seatholders and prevent off floor market making, I did not think IB or other retail shops would take the bait unless they were trying to cross subsidize their prop operations.
Yes I know nominally the rule is to try to pare back the excessive message rates that tax bandwidth and computer power and perhaps a vane wish that bluffing will be reduced. I doubt it will accomplish either. If you have seen the benchmarks, you know the ES is not really going to see much of a reduction in message rates, as its message rate is currently well below 25:1 basic rule. The currently 1:1 and 10:1 existing rates cannot really be pared back much. Does bluffing really cost any of you money, really? Seems rather obvious that of the 1600 or so times a day the bid/ask shifts on es, very few shifts occur for more than 400 contracts regardless of the size of the bid or ask being hit, and if they will hold to their full size, they invariably withstand the first hit of 400. How hard is that?