Going over the 390 is a non starter for me. I've done it once and spent 3 months dealing with it. Bottom line is the fees are a minor issue - its your fills or fill rate that is affected.
The real reason for this rule imo is quite simply to identify the "better" retail traders (assuming there is a correlation of success to orders/volume). Quite possibly a bad assumption. Once identified - the orders are treated differently. Almost like they go down a different pipe. These HFT/MM's act like a casino. Identify traders/gamblers - and then don't trade/take bets against who you think is sophisticated.
In fact I see examples every day of traders who are either professional customers or away market makers and generally speaking their orders are ignored by the hft's/mm. i.e - an option with a $5 bid $6 ask. They place a BUY order at $5.70 and don't get a fill and cancel. I immediately place an order to BUY at $5.60 (regular customer) and get an instant fill (with no change to the underlying).
Some of these longer dated options have a $5+ spread. If you want to trade them as a regular customer AND want to get a decent fill - then you could easily cancel replace your order 20 times before you get a fill. 20 orders like that per day and you are magically over this limit and you could have only traded a few hundred contracts.
But hey MR CBOE - if you don't want that business - I will trade foreign equity options, SSF's, futures, futures options and equities instead. No limits on any of these products (in terms of fees). In fact my fees/per generally go down the more I trade them.......lol
Message to the CBOE: Its 2020. Time to update this rule or eliminate it
The real reason for this rule imo is quite simply to identify the "better" retail traders (assuming there is a correlation of success to orders/volume). Quite possibly a bad assumption. Once identified - the orders are treated differently. Almost like they go down a different pipe. These HFT/MM's act like a casino. Identify traders/gamblers - and then don't trade/take bets against who you think is sophisticated.
In fact I see examples every day of traders who are either professional customers or away market makers and generally speaking their orders are ignored by the hft's/mm. i.e - an option with a $5 bid $6 ask. They place a BUY order at $5.70 and don't get a fill and cancel. I immediately place an order to BUY at $5.60 (regular customer) and get an instant fill (with no change to the underlying).
Some of these longer dated options have a $5+ spread. If you want to trade them as a regular customer AND want to get a decent fill - then you could easily cancel replace your order 20 times before you get a fill. 20 orders like that per day and you are magically over this limit and you could have only traded a few hundred contracts.
But hey MR CBOE - if you don't want that business - I will trade foreign equity options, SSF's, futures, futures options and equities instead. No limits on any of these products (in terms of fees). In fact my fees/per generally go down the more I trade them.......lol
Message to the CBOE: Its 2020. Time to update this rule or eliminate it
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