Has anything changed with either the laws or IEX's plan since then?
Update: IEX did indeed change their proposal to remove the favored order routing. Which still affects trades in other exchanges, and still affects negatively effects traders on all markets, but at least its "fair" now.
It's not just trading on behalf of a client. Even if you're trading directly for yourself, you're still legally obligated not to "trade-through" a displayed price. The idea is to protect the person who placed the displayed order, not yourself or your client.
> IEX intentionally, massively delays answering back unless you pay them buckets of money
You can't pay them to avoid the delay. They delay all outgoing direct-to-trader information and all incoming orders or cancels.
The difference between what IEX does and just placing your stock exchange 38 miles from everyone else's (350us at light speed in fiber) is that while they delay incoming orders and outgoing data, IEX itself listens to data coming in from other exchanges with no delay, and uses that 350us look into the future to re-price orders before anyone else can interact with them.
> The idea is to protect the person who placed the displayed orde
I'm afraid I don't understand what the first quote means and how the person in the second one is protected. An explanation would be much appreciated.
Also, IEXs delay is less than the delay between existing exchanges because of speed of light limits, so massively seems inappropriate.
The side-effects of this law and because of it not being able to achieve a 'fair' price was why IEX was created.
Edit: This is neither a pro nor anti comment. It is a factual comment, of the motivation to create IEX.
Yeah they are really looking out for the small investors. How very considerate.
Small investors benefit from HFT and related technologies, which is why, eg, Vanguard is pro-HFT. Investment banks are harmed by it, which is why, eg, Goldman is anti-HFT.
I don't think the goal is to be deceptive, but the biases of the source are going to come through. Traders at banks are going to much more charismatic and gregarious than traders at HFT firms so it's not surprising that their story rings louder.
[0] I'm not talking about explicit quid-pro-quo arrangements, but something along the lines of http://www.paulgraham.com/submarine.html
Is IEX actually doing things in good faith or are they just playing off of people that are scared?
The unfortunate problem (that's hard to resolve) is those executing on agency will always be at a disadvantage to those executing on principal. For example if someone wants to buy 5000 shares, they can route in a way that risks them buying 8000 to get better prices (by sending extra orders to dark pools, etc), someone executing on agency can never do that and so it might not make sense for them to route to dark pools, but almost all of the routers do that (fidelity, schwab, etc) so they disadvantage some of their customers (although they do advantage the smallest customers). Basically I think ultimately the reg-nms order protection is probably a little too rigid of a structure to fit the diversity of behavior into. I'm not really sure what they're long term hope is. I do find equities to be basically the most fair trading ground on the exchange (which is why they had any foothold at all). It would be nice if they were trying to disrupt the really expensive trading markets like fixed income where the spreads are much wider compared to the risk being exchanged and the dealers have so much leverage that they won't support anybody who is trying to cut into that spread.
Flash Boys: NSF? Please elucidate.
"If the goal is to avoid high-frequency trading, why not use a distributed database"? Maybe because that would have absolutely zero impact whatsoever on high-frequency trading?
(Also, the goal isn't really to avoid high-frequency trading, and it's quite likely IEX will create more opportunities for high-frequency trading, not fewer, but that's another matter.)
It's slowness?
The transparency of the consolidated order book?
I place orders on Counterparty a lot, which offers a decentralized asset exchange that settles to the bitcoin blockchain. It would be nice settle stock trades on something like that, slow, too slow, but it would be a nice option.
To this, the SEC issued an interesting response: addressing concerns about the legality of speed bumps, the SEC separately said that delays of less than one millisecond are consistent with its Regulation NMS.
According to the SEC [1], IEX's 350 microseconds delay is negligible, and thus the market is automated and the quote is protected. The practical interpretation is that the SEC has set a ceiling for what it deems the speed race among HFT firms (with fiber optics, microwaves, lasers...)
So with this decision, the SEC has capped what technological advancement in trading can achieve going forward, as now a 350ms delay will become the norm, while anything below 1 millisecond is deemed a "de minimis" delay. Which is no good for HFTs, where microseconds can mean all the difference between profit and loss.
[1] https://www.sec.gov/divisions/marketreg/automated-quotations...
* IEX is still FIFO, as you point out about the race in response to external events. If Katsayuma really wanted to wipe out latency arb, he should have introduced some randomization and batching into the matching engine. I'm not sure how that would hold up from a regulatory perspective though.
* IEX quote updates will be 350us slower than any other update because of the additional input latency, which means that their protected quotes will always lag behind the market on a price flip. The amount of time that a price level is still protected on the SIP, yet practically gone, will increase as a result. This will increase the amount of time that DAY ISO orders are necessary for establishing the new price level, and therefore will benefit the HF shops which can leverage DAY ISOs the best. This also possibly creates a moral hazard for noncompliance.
* Other exchange owners have expressed interest in adopting a shoebox-like system, because of the expectation that delayed quotes will _force_ more market participants to trade on that exchange. If multiple systems start generating lagged quotes, the first problem continues to get worse.
* IEX's pegged order type relies on the SIP. But now that IEX itself will become a part of the SIP, the shoebox delay will have a feedback effect of lagging its own peg updates. Likewise, if other updates start delaying their output, IEX pegs may become less useful. I'm not exactly sure what the net effect of this will be (after a few years of other exchanges adapting)... but I don't expect it to be "good" for the system as a whole.
In general, I believe that artificial introduction of latency into the National Market System seems only to serve special interests: advanced technological traders (usually HFT itself), and the exchanges which enact the artificial latency.
“Today’s decision will test and potentially reverse the gains in fairness, efficiency and transparency that have been made to our markets over the last decade. We must be vigilant to identify unintended consequences, and firm in our commitment to equitable and consistent treatment for all investors.” [1]
[1] http://www.reuters.com/article/us-usa-sec-iex-idUSKCN0Z32NM