Dark Trading at the Midpoint: Does SEC Enforcement Policy Encourage Stale Quote Arbitrage? Robert P. Bartlett, III1 Justin McCrary University of California, Berkeley University of California, Berkeley, NBER Abstract: Prevailing research posits that liquidity providers bypass queue lines on exchanges by offering liquidity in dark venues with de minimis sub-penny price improvement, thus exploiting an exception to the penny quote rule. We show that (a) the SEC enforces the quote rule to prevent sub-penny queue-jumping in dark pools unless trades are “pegged” to the NBBO midpoint and (b) the documented increase in dark trading due to investor queue-jumping stems from increased midpoint trading. Although encouraging pegged orders can subject traders to stale quote arbitrage, we show it could have affected no more than 5% of our sample midpoint trades. Draft Date: October 26, 2016 JEL codes: G10, G15, G18, G23, G28, K22 Keywords: latency arbitrage, high-frequency trading; dark pools; tick sizes; market structure Statement of Financial Disclosure and Conflict of Interest: Neither author has any financial interest or affiliation (including research funding) with any commercial organization that has a financial interest in the findings of this paper. The authors are grateful to the University of California, Berkeley School of Law, for providing general faculty research support. 1
[email protected], 890 Simon Hall, UC Berkeley, Berkeley CA 94720. Tel: 510-542-6646. Dark Trading at the Midpoint: Does SEC Enforcement Policy Encourage Stale Quote Arbitrage? Abstract: Prevailing research posits that liquidity providers bypass queue lines on exchanges by offering liquidity in dark venues with de minimis sub-penny price improvement, thus exploiting an exception to the penny quote rule.