Quote from Ivanovich:
Article from Zerohedge written by Dennis Dick of Bright Trading, LLC:
My firm, Bright Trading LLC, recently provided comments to the SEC concerning a predatory trading practice that is compromising the NBBO. It is the practice of using undisplayed trading centers to step in front of displayed orders by an infinitesimally small amount. Today I was trading a very thin, illiquid stock where these predatory trading practices run rampant. I decided to document the sequence of events.
Time & Sales
Time Last Share (100 lots) Exchange
10:19:35 14.04 1 FINRA TRF
10:19:48 14.04 1 FINRA TRF
10:20:00 14.0399 1 FINRA TRF
10:20:14 14.0399 1 FINRA TRF
10:20:28 14.0399 1 FINRA TRF
10:20:43 14.0299 1 FINRA TRF
10:20:58 14.05 1 FINRA TRF
10:21:15 14.0399 1 FINRA TRF
10:21:31 14.0399 1 FINRA TRF
10:21:49 14.0299 1 FINRA TRF
10:22:06 14.0199 1 FINRA TRF
10:22:22 14.05 1 FINRA TRF
10:22:41 14.05 1 FINRA TRF
10:23:00 14.0499 1 FINRA TRF
10:23:18 14.05 1 FINRA TRF
10:23:37 14.05 1 FINRA TRF
10:23:57 14.05 1 FINRA TRF
10:24:15 14.05 1 FINRA TRF
10:24:36 14.05 1 FINRA TRF
10:24:56 14.0299 1 FINRA TRF
10:25:16 14.0299 1 FINRA TRF
10:25:34 14.03 1 NYSE
10:25:34 14.04 1 NYSE
10:25:37 14.0399 1 FINRA TRF
10:25:58 14.0299 1 FINRA TRF
10:26:20 14.0299 1 FINRA TRF
10:26:40 14.0199 1 FINRA TRF
10:27:02 14.0199 1 FINRA TRF
10:27:24 14.0299 1 FINRA TRF
10:27:44 14.0299 1 FINRA TRF
10:29:58 13.99 10 FINRA TRF
Sequence of Events
Time Event
10:19:34 I place an order to sell my 300 shares of RBS.PRE at $14.05
10:19:35 An algorithmic trader steps in front of my order at 14.04 (offering on NYSE exchange).
10:19:35 The stock trades at 14.04. The displayed 14.04 offer is not filled as the quote remains the same, despite the stock trading at that price. The trade was reported on FINRA TRF (FINRA Trade Reporting Facility). This means it was traded off the exchange.
10:19:48 Stock trades again at 14.04, reported on FINRA TRF, displayed offer is again not filled.
10:20:00 Stock trades at 14.0399, in front of displayed offer of 14.04.
10:20:14 Stock trades again at 14.0399, in front of displayed offer of 14.04.
10:20:18 Stock trades for a third time at 14.0399. Displayed seller is again not filled.
10:20:38 Frustrated, I move my ask price from 14.05 to 14.03. I am now the best offer.
10:20:43 Stock trades at 14.0299 in front of my 14.03 offer.
10:20:50 Frustrated, I cancel my order. The best displayed offer is now 14.05.
10:20:58 Stock trades at 14.05, but the displayed offer is again not filled. Trade is reported on FINRA TRF (off exchange). The displayed offer moves down to 14.04.
10:21:15 Stock trades at 14.0399 in front of displayed 14.04 offer.
10:21:31 Stock trades again at 14.0399 in front of displayed 14.04 offer.
10:21:41 I decide to try and offer my 300 shares again at 14.03.
10:21:49 Stock trades at 14.0299 in front of my displayed 14.03 offer.
10:21:55 Frustrated I move my offer down to 14.02.
10:22:06 Trade goes off in front of me again at 14.0199.
10:22:15 I move my offer back to 14.06. Another trader offers in front of me at 14.05.
10:22:22 - 14.05 trades 7 times, and 14.0499 trades once, but displayed offer is not
10:24:36 filled on any of these orders.
10:24:44 I move my offer down to 14.04. Other trader immediately steps in front of me and offers stock at 14.03.
10:24:56 and
10:25:16 14.0299 prints twice, displayed offer not filled again.
10:25:34 Displayed offer 14.03 gets filled, and I get filled on 100 shares at 14.04. Hallelujah!!
10:25:37 14.0399 trades in front of my remaining 200 shares offered at 14.04. Another trader places sell order at 14.03.
10:25:58 14.0299 trades in front of displayed 14.03 offer.
10:26:20 14.0299 trades in front of displayed 14.03 offer again.
10:26:39 I move my offer from 14.04 to 14.02.
10:26:40 14.0199 trades in front of my displayed 14.02 offer.
10:27:02 14.0199 trades in front of my displayed 14.02 offer again.
10:27:10 I move my offer back to 14.03.
10:27:24 14.0299 trades in front of my displayed 14.03 offer.
10:27:44 14.0299 trades in front of my displayed 14.03 offer again.
10:27:50 I give up and move onto another trade. Later I am filled at 14.03, and the stock proceeds to go higher (only reason I am filled).
Who is this market participant stepping in front of my displayed offer? Who is this market participant intercepting the buy orders that are trying to take my displayed offer? Who is this market participant forcing me to pay the spread and hit the bid below? According to the implied exemption given under SEC rule 612, the only market participants capable of trading in sub-pennies are broker-dealers, to offer price improvement. Is this $0.0001 price improvement justification for compromising the displayed quote? This isnât an isolated event, these events happen continuously every day in this two-tiered market structure. This is a crime of epic proportions, and our regulators need to deal with this immediately.