So I got interested in this question and asked a buddy of mine who does equity market making. The general answer is "it depends on the broker, the order and order routing".In any case, the question is - do HFTs get actual stop orders from brokers like TD and RH?
Specifically, a directed complex order (e.g. stop, stop-limit or mid-peg sent to a specific exchange or dark pool) will be sent to that exchange and will not be visible to anyone beyond visibility offered by the exchange for that order type. I.e. if you are sending something like hidden stop-limit order to whichever exchange implements it, nobody but the exchange will see your order until it is triggered at which point it will be posted to the regular order book as a limit. All good, fairness and beauty rule the world.
However, if you are relying on your brokers implementation of a complex order (e.g. trailing stops on RH) it is very likely that the orders are accepted and sent directly to the PFOF counterparty for execution. It is probably specified in the small print that is was signed by the poor sod when he opens the account. Obviously, the orders would still be subject to normal trade-through protection once triggered (PFOF is not an exemption from regulations by any means), however you can safely expect to get negatively selected a fair bit more. Practically, this means that the RH user using a trailing stop is actually going to see an improvement over NBBO on his stop fills, yet the stock will move against him right after a lot of the time.