Interactive brokers forex minimum trade size for conduit

STP Features Even an STP broker is no dealing desk, but unlike the ECN, which has a similar functioning with direct access to the interbank market at the real price applied, it does not provide the same transparency in terms of information. It is a system in which the transfer and execution of orders takes place in a fully computerised manner.

Straight Through Processing guarantees direct access to the market and rapid execution of orders but not the guarantee of execution under any market conditions. They generally tend to apply a system of profit derived from spreads or spreads plus variable commissions. Support In case of doubt it is better to speak in the language you know best. This allows you to better articulate the question you ask and to go deeper into the subject by asking further questions, should the need arise.

For this reason it is good to choose a broker who has a website in english and offers assistance and support in english. We also recommend a broker that allows you to communicate through different channels: telephone, chat, email,… In this way, depending on your mood or urgency you can use one channel of communication rather than another. Financial Leverage Leverage is what has revolutionized the way of trading, because it has given ordinary people the opportunity to trade and invest with little money, sometimes even less than 10 euros.

Before leverage this was unthinkable, and it took a lot of money to invest. Nowadays, however, thanks to the leverage, to buy the same contract you only need euros in your account, sometimes even less. So, with euros, I can buy a , euro contract. It is therefore clear that by doing so the gains but also the losses are greatly amplified. As far as you are concerned, it is good to choose a broker that offers high leverage, this way you will not have to have so much money in your trading account.

For example, to trade in the Forex market, bank brokers generally offer low leverage, such as 1 to 20 or 1 to 50, whereas specialist brokers offer much higher leverage, such as 1 to or 1 to or even more. It is therefore clear that the latter are the best choice. A synonym for leverage is margin, so when we are talking about margin, in practice we are talking about leverage, and vice versa.

Numerically, the margin is given by divided by the leverage. For example, saying leverage 1 to or margin 0. As you can see the leverage is 1 to , because with euros you buy something that costs times as much, and the margin is 0. Trade-Out Trade-out is a subject closely related to leverage.

Many brokers also call it margin call. In practice it represents the level above which the trade is automatically closed at a loss, even if you have given no order to close it. It is therefore an automatic protection. To buy this contract you are asked for 1, euros as margin because you have a leverage of 1 to , so the margin is 1.

Suppose you make a mistake and you start losing 3, euros, then 4,, then 5, and so on until you reach the point where you are losing 9, euros: now you just need to lose 1 cent more than this amount, and the operation will be closed automatically.

This percentage refers to the margin, which is 1, euros. Of course these are very rare scenarios. Those who invest, knowing what they are doing, are virtually never in these situations, because they always have the situation under control and therefore never reach the trade-out level.

In fact, all you need to do is use stop loss and the problem is solved. However, for the purposes of choosing a broker, it is good to choose a broker that offers a low level of trade-out, in this way you can be more free in your operations and use your money more. Trading Platform Forex platforms are basically divided into three types: standalone, web-based and mobile.

Stand alone. These are the platforms that physically must be downloaded and installed on your computer like any normal program like Metatrader 4 and 5. They are generally the most used and the most complete that allow you to trade in the most professional way. Web Based. These are the platforms through which you can trade directly online without having to download anything to your computer.

The main advantage of these platforms is of course the flexibility, i. These are the platforms that allow you to trade through mobile devices, i. Each broker for each market has a minimum trade size and a maximum trade size, and you need to get to know them to see if they can limit your operations. For this reason it is good to choose a broker that offers a very low minimum trade size and a very high maximum trade size.

Limitations You need to know if the broker applies any restrictions, of any kind and even momentarily, to your operations. This is because otherwise you may find out when you are operating and then when it is too late. In any case, for the purposes of your choice, it is good to choose a broker who does not apply limitations to your operations. For example, if you pour 1, euros into your account you get 2, euros, in fact the broker gives you 1, euros. The bonus can be a good thing, but in some cases it can also have negative aspects, so always be well informed if you want to take advantage of a bonus or another promotion.

All things being equal, it is a good idea to choose a broker who offers a high bonus or advantageous promotions, as long as, as mentioned before, the bonus has no negative aspects, i. Perfect legality is more important than giving away 1, euros! STEP 3 — Select the forex broker according to costs Generally speaking, brokers specialising in a given trading sector are the ones who offer the best offer also with regard to the specific costs of that way of trading.

So, after selecting a few brokers based on your legal information and the way you trade, the time has come to select the one that is most cost-effective, i. And therefore, not all ways of trading cost the same. For example, whoever invests in the very short term for the same profit will have to pay the broker more than who invests in the long term, simply because he will have opened many more trades.

So the third step you need to take in order to choose the best broker is to be well informed about all the costs of trading. In particular you need to examine the following points: Spreads The spread is the difference between the price at which you buy and the price at which you sell a particular financial instrument. The spread varies from broker to broker, so different brokers have different spreads.

For the purposes of your choice, all things being equal, you must choose a broker who offers a low spread, especially if you are scalping or short-term. As with the spread, commissions vary from broker to broker, and depending on the market some brokers do not charge any commission.

Again, this is very simple, all things being equal, you must choose a broker who offers low commissions, or even zero commissions, as these will negatively affect the final balance of your operations, especially if you operate with low capital. In fact, if you operate on certain markets with certain financial instruments your transactions will be subject to interest. The mechanism is very simple, by opening a trade and keeping it open sometimes you receive interest and sometimes you pay it.

The point is that very often brokers charge you whether you have a long open position or a short open position, so in practice you never receive interest. This is because these brokers add a commission to the interest rate you should receive.

Because this commission is almost always higher than the interest you receive, you are forced to pay. For example if you receive 1 euro interest but pay 2 euro commission on this interest, you actually have to pay the broker 1 euro. This is why with certain brokers you pay both when you receive interest and when you pay it. Answer: Yes, the Commission has issued an order exempting non-convertible preferred securities from Rule a.

Given these characteristics, non-convertible preferred securities typically are priced based on yield and trade more like fixed income instruments than like common stocks. Although granting an exemption from Rule for non-convertible preferred securities, the Commission emphasized that transactions in such securities remain subject to all other applicable regulatory requirements.

For example, broker-dealers continue to owe a duty of best execution to their customers, particularly retail customers, with respect to their handling and execution of customer orders in non-convertible preferred securities. The broker-dealer agrees to sell the shares to the customer at the volume-weighted average price of the accumulated shares, but also guarantees an execution of the order at no worse than a specified price.

At the time the broker-dealer commits to execute the order, it is not reasonably determinable whether the execution price will be the volume-weighted average price or the guaranteed price. The broker-dealer subsequently accumulates the , shares at a volume-weighted average price that is higher than the guaranteed price and therefore sells the shares to the customer at the guaranteed price. The transaction price for the customer buy order is higher than the national best offer at the time of execution, and therefore the transaction does not qualify for the stopped order exception in Rule b 9.

Does the transaction nevertheless qualify for the benchmark exception in Rule b 7? Answer: Yes, the transaction qualifies for the benchmark exception because it was not based, directly or indirectly, on the quoted price of the NMS stock at the time of execution and the material terms of the order were not reasonably determinable at the time the broker-dealer committed to execute the order.

In particular, the execution price of the order was not reasonably determinable at the time the broker-dealer committed to execute the order and did not result in any reasonably determinable compensation to the broker-dealer. Rather, an order can be evaluated separately under each exception. Based on the particular facts and circumstances of a transaction, the transaction may qualify for both exceptions, only one of the exceptions, or neither of the exceptions.

If, for example, it is reasonably determinable that the order will be executed at the guaranteed price, the transaction would not qualify for the benchmark exception though it still could qualify for the stopped order exception, assuming it otherwise meets the terms of such exception. Moreover, if the guaranteed price was added to the order after it was originally accepted, the order would need to be evaluated at the later time to determine whether an execution at the guaranteed price would qualify for the benchmark exception.

If the accumulated quantity were less than the full size of the order, the benchmark exception could apply only to the quantity that was accumulated, assuming all other terms of the exception were satisfied. The negotiations may occur through a conversation e.

The parties agree to a price that is at or within the best protected quotations at some point during the negotiations. After the parties agree to this price, the transaction information is captured in an automated system of the broker-dealer in a reasonable time. In some transactions, particularly for securities with volatile quoted prices, the individually negotiated price may not be at or within the best protected quotations at the time the transaction terms are captured in the automated system.

If the transaction is affirmed pursuant to one of the alternative policies and procedures, the broker-dealer considers the transaction as a non-trade-through transaction for purposes of Rule Do these alternative policies and procedures for handling agency block transactions with individually negotiated prices comply with Rule a? Answer: Yes, either of the alternative policies and procedures for affirming that the individually negotiated price of an agency block transaction was at or within the best protected quotations at some point during the second period up to and including the time the transaction terms are captured in an automated system of the broker-dealer would be a reasonable policy and procedure to prevent trade-throughs under Rule a.

In this context, the broker-dealer is acting as agent to arrange large transactions at prices that generally will be favorable for each party i. The broker-dealer thereby is performing a useful service in enabling its customers to find contra-side liquidity in large sizes. Given the desire of some block customers to negotiate prices individually, either of the alternative policies and procedures is a reasonable way for the broker-dealer to address the practical difficulties of individually negotiating a price that is intended to be at or within the best protected quotations and capturing the transaction terms in an automated system.

To meet the regular surveillance requirement of Rule a 2 , the broker-dealer should periodically check to assure that its personnel are accurately affirming prices within the second period, or that its automated system is accurately affirming prices within the second period.

After the customer and trader manually agree to a price, the trader immediately begins inputting the transaction information into an automated system of the broker-dealer and completes the input in a reasonable time.

Would the transaction qualify for the stopped order exception of Rule b 9? Under Rule a 1 , a trading center is required to establish, maintain, and enforce written policies and procedures that are reasonably designed to assure compliance with the terms of the exceptions in Rule b. In particular, the broker-dealer reasonably can refer to quoted prices at the time of input to determine compliance with Rule for manually negotiated transactions.

Consequently, if the broker-dealer has agreed to execute a customer order at a manually negotiated price that is underwater at the time of input into an automated system, the transaction would meet the underwater price requirement of Rule b 9 iii , notwithstanding that the broker-dealer did not document the order as a stopped order at the outset of the transaction. Section 4: Order Routers Question 4.

Answer: Order routers will have three basic tools, if they choose to use them, to control the handling of their orders to comply with Rule Use of a limit price precludes any execution at a price inferior to such price. Use of an IOC designation triggers the requirements for automated quotations set forth in Rule b 3 of Regulation NMS, particularly the requirement that the trading center provide an immediate response to the order see FAQ 2.

The response must be a fill, in full or in part, or a non-fill, and a cancellation of any unfilled balance of the order, without routing the order away to another trading center. Finally, use of an ISO designation enables the destination trading center to execute the order immediately without regard to better-priced protected quotations displayed by automated trading centers. When an order is designated as an ISO, the broker-dealer routing the order must assume the responsibility for transmitting additional orders, as necessary, to execute against any better-priced protected quotations see FAQs 4.

The ISO designation also informs the destination trading center that the fees for any order execution should not exceed the limitation of fees set forth in Rule c , unless the order router affirmatively expresses its willingness to accept an order execution beyond the scope of the fee limitation see FAQ 2.

The coordinated use of a limit price, IOC designation, and ISO designation should be particularly valuable for those who wish to conduct automated best-price routing strategies. Question 4. Answer: Rule a 1 requires trading centers to establish, maintain, and enforce policies and procedures that are reasonably designed to assure compliance with the terms of the ISO exception.

Similarly, Rule c requires trading centers and broker-dealers to take reasonable steps to establish that ISOs meet the requirements of Rule b In structuring their ISO routing arrangements, trading centers and broker-dealers should reasonably address the potential for systems problems.

In particular, the routing arrangements should be highly reliable and incorporate appropriate policies and procedures to monitor performance of routing systems to affirm that they are functioning properly. Moreover, if a primary routing system experiences problems that render it incapable of routing ISOs to execute against one or more better-priced protected quotations, a trading center or broker-dealer will not be able to continue to take advantage of the various ISO exceptions unless its routing arrangements have incorporated at least one reasonable alternative means of routing the required ISOs to the appropriate automated trading centers.

Answer: Yes, a broker-dealer responsible for routing ISOs is permitted to retain the services of another entity for assistance in meeting the requirements of Rule , but such broker-dealer would remain ultimately responsible for compliance with the Rule. Answer: Yes, an order router that does not intend to sweep any inferior prices can designate a single order as an ISO when it is routed to a trading center displaying the best-priced quotation for a stock. The ISO designation will allow the destination trading center to execute the order immediately, even if another trading center displays a better-priced protected quotation after the ISO is routed and before the ISO is executed by the destination trading center.

The definition of an ISO requires that, simultaneously with the routing of an ISO under subparagraph i of Rule b 30 , one or more additional ISOs are routed under subparagraph ii , as necessary, to execute against the full displayed size of any better-priced protected quotations. If there are no protected quotations with better prices than the limit price of the subparagraph i ISO at the time of routing, then it is not necessary to route any additional ISOs under subparagraph ii.

In addition, the size of the subparagraph i ISO need not equal or exceed the full displayed size of the protected quotation. For example, if three trading centers are displaying protected bids that equal the national best bid for a stock, it would be appropriate for a best-price order router to route a sell ISO of any size to any one of them, to any two of them, or to all three. In each case, there would be no better-priced protected bids that necessitated the routing of additional sell orders.

Note, however, that the use of an ISO designation discussed in this question and response is limited to best-price order-routing strategies that will not sweep any inferior prices. In contrast, whenever an order router intends to sweep one or more inferior prices, an ISO must be routed to execute against every better-priced protected quotation.

For example, if a trading center intends to use the exception in Rule b 6 to enable such trading center to execute a trade at an inferior price, the trading center must route ISOs to execute against the full displayed size of all better-priced protected quotations. Whenever the relevant rule provision requires that an ISO be routed to execute against the full displayed size of a protected quotation, such ISO must be routed directly to the SRO trading facility that is directly displaying the protected quotation in the Network quotation stream.

If the price of the protected quotation at Trading Center A does not change, is it permissible for such order router to continue to route ISOs to other trading centers for one full second, without routing a new ISO to execute against the same-priced protected quotation at Trading Center A? Answer: Yes, waiting one full second to route a new ISO to an unchanged price at a trading center after receiving a no-fill or partial fill cancellation of a previous ISO seeking to execute against a protected quotation at such trading center would qualify as a reasonable policy and procedure under Rule a 1 to prevent trade-throughs, as well as a reasonable step under Rule c to establish that orders meet the requirements for ISOs set forth in Rule b In the NMS Release, the Commission recognized the practical challenges of implementing intermarket price priority at the level of sub-second time increments.

Particularly for active stocks, many orders can seek to execute against a single displayed quotation, many trades can be executed, and many quotations can be updated, all within a single second. In recent years, industry participants have acquired substantial practical experience with policies and procedures for automated best-price routing strategies. After the compliance date for Rule , the Staff believes that trading centers and broker-dealers should continue to have considerable flexibility in adapting such policies and procedures to address the practical challenges of implementing best-price routing strategies in compliance with the Rule.

As long as such policies and procedures are reasonably designed to route orders to execute against the full displayed size of protected quotations prior to the execution of a trade at an inferior price, it will be appropriate to use the ISO designation as a means to implement the best-price routing strategy. In addition, the scope of a problem can vary widely e. The self-help exception is designed to promote efficient intermarket price priority by providing a flexible tool that generally will allow trading to continue while affected trading centers identify the problem and respond appropriately.

A trading center that elects to use the self-help exception must notify the trading center whose quotations are bypassed. The notice can be sent by electronic mail and must be sent immediately upon use of the exception. The self-help notice is intended to give the bypassed trading center an opportunity to assess whether its systems are in fact malfunctioning. The notice requirement also is generally intended to facilitate communications between the electing trading center and the bypassed trading center that could help identify the source of the problem and promote its resolution.

To meet this objective, the notice should, at a minimum, provide a mechanism for communication with someone at the electing trading center who will be able to respond to inquiries concerning the notice. As noted in FAQ 2. Systems Assessment and Response. When an order router initially fails to receive immediate responses to IOC orders from the destination trading center, the precise source of the problem often may not immediately be clear.

The problem could be located in the internal systems of the destination trading center, but it also could be located in the internal systems of the order router or in the connections that the order router used to access the destination trading center. As discussed in FAQ 4. These arrangements should include appropriate policies and procedures to monitor the performance of routing systems to affirm that they are functioning properly. An order router is not entitled to bypass protected quotations pursuant to the self-help exception if it has reason to believe that an order-response problem is not attributable to a problem with systems for which the destination trading center is responsible.

For example, if the order router has experienced repeated problems with its own systems in reaching a particular destination trading center, it is not entitled to elect the self-help exception when such problems reoccur. Moreover, an order router that appropriately elects to initiate use of the self-help exception cannot simply assume at that point that a problem lies elsewhere. The order router must assess whether the cause of a problem lies with its own systems or connections and, if so, take immediate steps to resolve the problem appropriately.

The NMS Release states that a trading center must adopt objective parameters to govern its use of the self-help exception, noting that the repeated failure of a destination trading center to respond within one second to an incoming IOC order after adjusting for order transmission time would justify use of the exception. Such policies and procedures should address the specific circumstances that will trigger the exception, the stock or stocks that will be affected, and the specific circumstances that will terminate the exception.

In recent years, many market participants have developed best-price routing practices and have considerable experience in dealing with trading centers when systems problems occur. The Staff anticipates that many of the policies and procedures already developed to deal with systems problems will qualify as reasonable parameters for use of the self-help exception. Such policies and procedures are likely to evolve as the securities industry gains experience interacting with Regulation NMS-compliant trading systems.

Answer: Yes, but only in the limited context of a failure to provide an immediate response to a specific protected quotation. The NMS Release notes that, as part of its policies and procedures to reasonably prevent trade-throughs, a trading center that routed an order to another trading center to access the full displayed size of a protected quotation would be entitled to continue trading without regard to such quotation until a response was received to the order.

If so, is any broker-dealer responsible for routing ISOs also entitled to bypass a trading center experiencing systems problems that would justify use of the self-help exception? Answer: When routing orders to meet the requirements for ISOs set forth in Rule b 30 , a trading center can decline to route orders to execute against the protected quotations of a trading center experiencing systems problems for which the routing trading center has triggered the self-help exception of Rule b 1.

This combined use of the self-help and ISO exceptions would be a reasonable policy and procedure under Rule a. For example, such a broker-dealer would need to adopt the reasonable policies and procedures required by Rule a 1 to implement the self-help exception including sending notice to the problem trading center — see FAQ 4. Is it permissible for a broker-dealer to use the services of another broker-dealer or trading center solely as a conduit for routing ISOs to one or more of such automated trading centers?

Answer: Yes, a broker-dealer can structure its ISO routing arrangements in a variety of ways to obtain connectivity to automated trading centers, including using another broker-dealer or trading center solely as a conduit through which to route ISOs. The requirements for these arrangements will depend on the specific structure chosen by the broker-dealer, and particularly on the extent to which the broker-dealer itself chooses to perform ISO routing functions.

Two of the essential steps in routing ISOs are, first, to take a snapshot of the relevant protected quotations and, second, to transmit to the appropriate automated trading centers any ISOs that are necessary to execute against such protected quotations under applicable rules. Rule c provides that the broker-dealer or trading center responsible for the routing of an ISO must take reasonable steps to establish that the ISO meets the requirements for ISOs.

For every ISO, there must be at least one broker-dealer or trading center that is responsible under Rule c. ISO routing structures can vary, and the identity of the broker-dealer or trading center that is responsible for routing an ISO can vary as well. As a result, all broker-dealers and trading centers that intend to participate in ISO routing arrangements must assure that, for any particular ISO, there is no confusion as to who is performing the necessary ISO functions and who is a responsible broker-dealer or trading center under Rule c.

In this structure, the originating broker-dealer i. Rather than establishing connections to all automated trading centers, such a broker-dealer might want to engage the services of another broker-dealer or trading center solely as a conduit through which to transmit ISOs to one or more automated trading centers.

This conduit routing structure is appropriate as long as the originating broker-dealer and the conduit broker-dealer or trading center have clearly delineated who will perform the necessary ISO routing functions. In particular, it should be clearly understood that the originating broker-dealer is the sole responsible broker-dealer under Rule c. Under these circumstances, the conduit broker-dealer or trading center could accept the ISO and handle it strictly in accordance with the instructions of the originating broker-dealer.

This conduit would not be a responsible broker-dealer or trading center under Rule c and would not be required to perform any other ISO functions e. In addition, if the conduit is a trading center that both executes trades and routes orders, the trading center must act solely in a routing capacity with respect to conduit ISOs, with no possibility of the trading center executing the conduit ISOs internally.

Will the SROs adopt a consistent approach in developing their rules? Answer: Each of the SROs has adopted rules incorporating a consistent approach to locking and crossing quotations. The rules do not restrict the display of automated quotations that lock or cross manual quotations. Question 5. For example, Rule b 6 requires that ISOs be routed to execute against all protected quotations with better prices than the price of the excepted trade-through transaction. Section 6: Data Policies and Procedures Question 6.

Given the latencies in transmitting data among these trading centers, as well as among broker-dealers that route ISOs to execute against the protected quotations displayed by trading centers, how will regulators assess the compliance of trading centers and broker-dealers with Rule ?

Question 6. Answer: As noted in FAQ 6. Such policies and procedures should address latencies in obtaining protected quotation data from the sources of such data. The Firm should implement reasonable steps to monitor such latencies on a continuing basis and take appropriate steps to address a problem immediately should one develop. In addition, a Firm should adopt reasonable policies and procedures for synchronizing its internal clocks, to the extent that it uses different clocks to assign time-stamps to its order, trade, and quotation data.

For example, different trading desks or systems at a Firm potentially could use different clocks to assign time-stamps to trades executed by such desks or systems, and these clocks could be different from the clock that is used to assign time stamps to protected quotations as they are received. The Firm should synchronize these internal clocks to enable the Firm to reasonably determine through its compliance procedures that the trading desks and order handling systems are executing trades and routing orders in compliance with Rule Answer: No, Rule does not require Firms to maintain a comprehensive database of Firm-Specific Quotation Data if 1 the Firm has implemented reasonable policies and procedures that include periodic review of its compliance with Rule , and 2 the Firm retains sufficient Firm-Specific Quotation Data to demonstrate the reasonableness of its Rule compliance reviews.

For these time periods, the Firm should maintain Firm-Specific Quotation Data so that the effectiveness of its policies and procedures can be adequately evaluated by regulatory authorities. Under existing regulatory requirements, Firms already are required to maintain their Firm-Specific Order and Trade Data.

As a result, Network Data constitutes a common reference point for quotations and trades in NMS stocks that will be readily available to the public, Firms, and regulatory authorities. As discussed in FAQs 6. As a practical matter, however, Firms should be aware that Network Data, as the single available common reference point for quotations and trades in NMS stocks, may be used by regulatory authorities, as an initial matter, to gauge their compliance with Rule generally.

For example, regulatory authorities may examine the Network data for comparable Firms to assess whether any Firm has an exceptionally high trade-through rate. If so, the relevant regulatory authority is likely to contact such Firm and ask for an explanation. The Firm will want to be in a position to demonstrate that its policies and procedures are reasonable. Firms also should recognize that the widely available Network Data could be a valuable external tool for assessing the effectiveness of their internal policies and procedures.

For example, an examination of the Network Data might reveal particular types of stocks, times of day, or types of trading conditions in which the Firm appears to generate a high rate of trade-throughs. The Firm could use this information to fashion its compliance reviews to assess these specific potential problem areas.

Such compliance reviews could reveal that the trade-throughs in the Network Data are false positives, as well as the explanation for why they appear to be trade-throughs in the Network Data. In either case, policies and procedures that include the use of Network Data may enable the Firm to provide a more effective response to regulatory inquiries.

Section 7: Miscellaneous Question 7. Eastern Time, but provides that regular trading hours can be changed to other times by the procedures established pursuant to Rule a 2. To date, these procedures have not been used to alter the to time period see FAQ 7. In addition, the access requirements of Rule a , b , and c are not limited to regular trading hours. Accordingly, the limitations are not operative when these entities are not disseminating a BBO.

Question 7. Answer: As noted in FAQ 7. It provides that the SRO maintaining the primary listing for an NMS security shall specify the regular trading hours for such security if they are to be other than to To date, the Commission has not approved an SRO rule modifying the definition of regular trading hours for purposes of Rule b The public then will have an opportunity to comment on the effect of the modification on compliance with Regulation NMS.

Answer: No, Rule and Rule do not apply to odd-lot orders or to the odd-lot portions of mixed-lot orders. Consequently, trading centers are permitted to establish their own rules for handling odd-lot orders and the odd-lot portions of mixed-lot orders. For example, although trading centers are not required to handle odd-lot orders or the odd-lot portions of mixed lot orders in accordance with the requirements for automated quotations set forth in Rule b 3 , they are free to incorporate such requirements in their rules if they wish to do so.

As a result, it is possible for such an exchange to receive a short sale order at a price that would be executable under Rule 10a-1 on that exchange, but not executable under Rule 10a-1 at another trading center using the consolidated tick test that was displaying a protected bid at a higher price. How should the exchange handle the short sale order?

Orders for which customers request special handling are excluded from the definition of covered orders in Rule b How should market centers treat ISOs in their Rule reports? By marking an order as an ISO, the router indicates to the destination trading center that it has simultaneously routed additional ISOs, as necessary, to any better-priced protected quotations. When the limit price of an ISO is equal to or better than the NBBO at time of order receipt, there can be no better-priced quotations elsewhere, and the router is simply seeking an order execution at the best displayed price or better.

In contrast, when the limit price of an ISO is inferior to the NBBO at time of order receipt, the customer is effectively instructing the trading center that it can execute the order at a price inferior to the NBBO, even if one or more trading centers are displaying better prices. This instruction constitutes a request for special handling at the trading center that excludes the ISO from the definition of covered order in Rule b The execution prices of such excluded ISOs are likely to be inferior to the execution prices of orders with the same limit prices that are not ISOs.

Consequently, excluding such ISOs from Rule reports should enhance the comparability of order execution quality statistics across different market centers. Section 8: Compliance Dates Question 8. Answer: The Commission has extended the original compliance dates for Rules and to a series of five dates for different functional stages of compliance. The revised compliance dates provide additional time for automated trading centers to finalize development of their Regulation NMS-compliant trading systems.

The extended dates also provide additional time for market participants to establish the necessary access to such trading systems and to gain practical experience with them. Question 8. Answer: The extended compliance dates are designed to provide all automated trading centers i.

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