ValueScreener

Lesson 5 of 9

How a free trade is paid for

Zero commission is not zero revenue. Where a retail broker's money comes from, what best execution requires, and which disclosure lets you check it.

Javier Sanz, founder

By Javier Sanz

Founder of ValueScreener. Built Ninety Nine, a securities services provider, and sold it to a tier-one global bank; ran operations and internationalization at Alpaca, the brokerage API.

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In one minute

  • A commission-free broker has several revenue lines, and order flow payments are only one of them. Interest on your cash is usually the largest.
  • The firm that pays for your order flow earns the spread on it, so the question is not whether it profits but whether your fill was worse for it.
  • Two public disclosures let anyone check: the broker's quarterly routing report, and execution quality statistics published by the venues.

A commission of zero is a price, not an absence of revenue. A broker that charges nothing to trade is being paid in other ways, and all of them are disclosed somewhere.

Knowing where the money comes from is not an accusation. It is the only way to read the incentive correctly, and the incentive is not always against you.

Where a commission-free US retail broker earns

  • Net interest on customer cash and margin lending55share of revenue
  • Order flow payments and market making20share of revenue
  • Subscriptions, data, securities lending, other25share of revenue
Illustrative round numbers, not any company's filings.

The proportions above are illustrative and vary enormously by firm and by the level of interest rates. The ordering is the part worth carrying: for most commission-free brokers, what happens to your idle cash matters more to their income statement than what happens to your orders.

What payment for order flow is

A wholesaler pays a broker a small amount per share for the right to execute its customers' orders. The wholesaler then fills those orders and keeps the difference between what it pays and what it receives, which is the spread.

Retail orders are attractive to a wholesaler for a specific reason: they are small and, in aggregate, uninformed about very short-term price direction. That makes them cheaper to trade against than orders from a firm that may know something, and the wholesaler will pay for access to them.

The obligation that constrains it

A broker owes its customers a duty of best execution. That duty is about the whole outcome, which includes price, speed, likelihood of execution and likelihood of settlement, and it is not satisfied by pointing at a payment received.

In practice a wholesaler usually fills a small retail order at or inside the published best bid and offer, which is called price improvement. The honest statement is that the arrangement can leave a retail investor better off on price than an exchange fill and simultaneously profitable for everyone in the chain, because the spread is wide enough to share.

The concern that survives all of that is a routing decision made on the basis of the payment rather than the fill. That is exactly what the disclosures exist to expose.

What it means for someone who trades twice a year

Very little, and that is the honest conclusion. The amounts per share are fractions of a cent, and a buy-and-hold investor crosses the spread twice a decade rather than twice a day.

Two things matter more and are in the same disclosures. The interest rate paid on uninvested cash, which is a real number that differs by several percentage points between brokers. And whether your shares are lent out, by whom, and who keeps the fee.

The generalisable point is the one this whole course keeps making. When a service is free, the revenue has moved rather than disappeared, and in regulated markets it has usually moved somewhere that must be published.

Check yourself

A broker charges no commission. What follows?

  1. It earns nothing from the account
  2. Its revenue comes from elsewhere, most often interest on cash and margin lending
  3. It must be routing orders badly

Show the answer

Answer: B.

Zero commission is a pricing choice. For most US retail brokers the largest revenue line is net interest, not order flow payments.

Why will a wholesaler pay for retail order flow?

  1. Retail orders are larger than institutional ones
  2. Small retail orders are, in aggregate, less likely to be informed about immediate price direction, so they are cheaper to trade against
  3. Regulators require the payment

Show the answer

Answer: B.

The wholesaler earns the spread and takes the inventory risk. Order flow that rarely moves against it in the next second is worth paying for.

Where can an investor check where their broker sends orders and what it is paid?

  1. Nowhere, the arrangements are confidential
  2. The broker's quarterly Rule 606 order routing report, which is public
  3. Only by asking the wholesaler directly

Show the answer

Answer: B.

Rule 606 requires quarterly public disclosure of routing venues and payments. Rule 605 statistics from the venues cover execution quality alongside it.

Sources

  • Rule 606 of Regulation NMS, requiring quarterly public reports on order routing, including payments received for order flow.
  • Rule 605 of Regulation NMS, requiring monthly execution quality statistics from market centers.
  • SEC investor education material on payment for order flow and on a broker's duty of best execution.

What this leaves out

  • The revenue split and the report table are illustrative. No broker's actual revenue mix, payment rate or fill quality is stated here, because those are firm-specific and change quarter to quarter.
  • Best execution is a legal standard whose interpretation evolves. Read the current rule text and the current enforcement record rather than this page.
  • Order flow payment practices differ by asset class and are banned in some jurisdictions outside the United States.
  • Nothing here is advice about any broker, any venue or any security.

Vocabulary, not a verdict

Lesson 5 of 9 of How a share actually trades. It teaches the word and the mechanic behind it. It does not tell you whether your own holdings clear anything, and a definition read correctly is still not a measurement: nothing here has opened an account you own.

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