PFOF Auditing

Sub-Penny Internalization Price Improvement Erosion

Audited by Cole Barrett • Topic: PFOF Auditing
⚡

Cole Barrett's Reality Check

The Unvarnished Bottom Line

"Brokers love putting big numbers on their marketing pages: 'We delivered $500 million in price improvement this year!' What they don't tell you is that they improved your fill by a hundredth of a penny on a ten-cent spread. They took 99.9% of the spread for themselves, gave you a fraction of a cent so they can check the regulatory box, and called it a customer benefit."

Interactive Simulator: Test the Math

Interactive Simulator: Compounding Fee & Tax Drag

Portfolio Balance ($) $100,000
Annual Expense / Tax Drag Rate (%) 0.75%
Direct Annual Deduction
$750.00 / yr
Siphoned directly from capital
25-Year Compound Loss
$94,200
Lost growth potential

Real-World Example: Scenario Breakdown

Examining the real numbers for: A retail trader purchasing 1,000 shares of an equity with an NBBO of $40.00 Bid / $40.10 Ask ($0.10 spread)

Execution Metric Lit Exchange Midpoint Match User PFOF Sub-Penny Internalized Client
Fee / Rate $0.0035/share DMA rate ($3.50 total) $0 advertised commission
Spread / Buffer Order routed directly to a lit exchange order book with midpoint routing instructions Order routed to an off-exchange wholesale market maker under a payment for order flow agreement
Execution / Status Matched against an independent institutional seller at the true $40.05 midpoint ($0.05 price improvement per share) Wholesaler provided an advertised 'price improvement' of $0.0001 per share, filling the order at $40.0999
Total Cost / Result Captured genuine midpoint price improvement on a transparent lit exchange Received token sub-penny price improvement while wholesaler monetized the spread

How Brokers Weaponize This Term

Review your broker's SEC Rule 605 execution quality reports. Look at the 'Price Improvement Percentage'. If your average price improvement on liquid stocks is less than 10% of the prevailing quoted spread, your broker's wholesalers are using sub-penny skims to capture spread revenue.

Broker Evaluation Matrix

Cole Approves

Interactive Brokers: Routes client orders through its SmartRouting engine to actively hunt for true midpoint executions across lit exchanges rather than sub-penny wholesale internalizers.

Read Audit →

Cole Flags / Avoids

Zero-Commission PFOF Apps: Routes 100% of retail market orders to wholesale internalizers that use token sub-penny price improvement to monetize customer flow.

View Trap Details →

Frequently Asked Questions

What is SEC Rule 612 (The Sub-Penny Rule)?

Rule 612 prohibits market participants from displaying quotes in increments smaller than $0.01 for stocks priced over $1.00, though wholesale internalizers are legally permitted to execute trades in sub-pennies off-exchange.

Why is the SEC proposing changes to sub-penny rules?

Regulators have proposed reducing the minimum tick size to half-pennies ($0.005) or smaller for liquid stocks, allowing public exchanges to compete directly with off-exchange wholesale internalizers.