PRIIPs Overview

BACKGROUND
In 2018, an EU regulation, intended to protect “Retail” clients by ensuring that they are provided with adequate disclosure when purchasing certain products took effect. This regulation is known as the Packaged Retail and Insurance-based Investment Product Regulation (MiFID II, Directive 2014/65/EU), or PRIIPs, and it covers any investment where the amount payable to the client fluctuates because of exposure to reference values or to the performance of one or more assets not directly purchased by such retail investor. Common examples of such products include options, futures, CFDs, ETFs, ETNs and other structured products.

It’s important to note that a broker cannot allow a Retail client to purchase a product covered by PRIIPs unless the issuer of that product has prepared the required disclosure document for the broker to provide to the client. This disclosure document is referred to as a Key Information Document, or KID, and it contains information such as product description, cost, risk-reward profile and possible performance scenarios. U.S. clients are not impacted by PRIIPs, so the issuers of some of the more popular U.S. listed ETFs often elect not to create a KID. This means that EEA Retail client may not purchase the product.

CLIENT CATEGORISATION
IBKR categorises all individual clients as “Retail” by default as this affords clients the broadest level of protection afforded by MiFID. Client who are categorised as “Professional” do not receive the same level of protection as “Retail” but are not subject to the KIDs requirement. As defined under MiFID II rules, “Professional” clients include regulated entities, large clients and individuals who have asked to be re-categorised as “elective professional clients” and meet the MiFID II requirements based on their knowledge, experience and financial capability.

IB provides an online step-by-step process that allows “Retail” to request that their categorisation be changed to “Professional". The qualifications for re-categorisation along with the steps for requesting that one’s categorisation be considered are outlined in KB3298 or, to directly apply for a change in categorisation, the questionnaire, is available in the Client Portal/Account Management.
 

Clearinghouse Restrictions on Cannabis Securities

Boerse Stuttgart and Clearstream Banking have announced that they will no longer provide services for issues whose main business is connected directly or indirectly to cannabis and other narcotics products.  Consequently, those securities will no longer trade on the Stuttgart (SWB) or Frankfurt (FWB) stock exchanges. Effective as of the 19 September 2018 close, IBKR will take the following actions:

  1. Force close any impacted positions which clients have not acted to close and that are not eligible for transfer to a U.S. listing; and
  2. Force transfer to a U.S. listing any impacted positions which clients have not acted to close and that are eligible for such transfer.

Outlined in the table below are impacted issues as announced by the Boerse Stuttgart and Clearstream Banking  as of 7 August 2018. This table includes a notation as to whether the impacted issue is eligible for transfer to a U.S. listing. Note that the clearinghouses have indicated that this list may not yet be complete and clients are advised to review their respective websites for the most current information.

ISIN NAME EXCHANGE U.S. TRANSFER ELIGIBLE? U.S. SYMBOL
CA00258G1037

ABATTIS BIOCEUTICALS CORP

FWB2 YES

ATTBF

CA05156X1087

AURORA CANNABIS INC

FWB2, SWB2 YES

ACBFF

CA37956B1013

GLOBAL CANNABIS APPLICATIONS

FWB2 YES

FUAPF

US3988451072

GROOVE BOTANICALS INC

FWB YES

GRVE

US45408X3089

INDIA GLOBALIZATION CAPITAL

FWB2, SWB2 YES

ICG

CA4576371062

INMED PHARMACEUTICALS INC

FWB2 YES

IMLFF

CA53224Y1043

LIFESTYLE DELIVERY SYSTEMS I

FWB2, SWB2 YES

LDSYF

CA56575M1086

MARAPHARM VENTURES INC

FWB2, SWB2 YES

MRPHF

CA5768081096

MATICA ENTERPRISES INC

FWB2, SWB2 YES

MQPXF

CA62987D1087

NAMASTE TECHNOLOGIES INC

FWB2, SWB2 YES

NXTTF

CA63902L1004

NATURALLY SPLENDID ENT LTD

FWB2, SWB2 YES

NSPDF

CA88166Y1007

TETRA BIO-PHARMA INC

FWB2 YES

TBPMF

CA92347A1066

VERITAS PHARMA INC

FWB2 YES

VRTHF

CA1377991023

CANNTAB THERAPEUTICS LTD

FWB2 NO  
CA74737N1042

QUADRON CANNATECH CORP

FWB2 NO  
CA84730M1023

SPEAKEASY CANNABIS CLUB LTD

FWB2, SWB2 NO  
CA86860J1066

SUPREME CANNABIS CO INC/THE

FWB2 NO  
CA92858L2021

VODIS PHARMACEUTICALS INC

FWB2 NO  

 IMPORTANT NOTES:

  • Note that the U.S. listings generally trade over-the-counter (PINK) and are denominated in USD not EUR thereby exposing you to exchange rate risk in addition to market risk.
  • Account holders maintaining PINK Sheet securities require United States (Penny Stocks) trading permissions in order to enter opening orders.
  • All users on accounts maintaining United States (Penny Stocks) trading permissions are required use 2 Factor login protection when logging into the account.

China Connect Northbound Investor ID Model

Background
In November 2017, the Securities and Futures Commission (SFC) and China Securities Regulatory Commission (CSRC) announced an agreement to introduce an investor identification regime for Northbound trading under Mainland-Hong Kong Stock Connect. This regime is intended to enhance regulatory surveillance of mainland-listed stock trading from Hong Kong and requires brokers to report the identity of clients submitting orders to either the Shanghai or Shenzhen Stock Exchange.  This regulation will be effective as of September 26, 2018.  Additional information is provided in the series of FAQs below.
 
What is the Stock Connect?
The Stock Connect is a collaboration between the Hong Kong, Shanghai and Shenzhen Stock Exchanges which allows international and Mainland Chinese investors to trade securities in each other's markets through the trading and clearing facilities of their home exchange.
 
What is Northbound trading?
Northbound trading refers to the trading of mainland-listed stocks (e.g., Shanghai and Shenzhen Stock Exchanges) from the Hong Kong Stock Exchange.
 
What information is being collected and reported?
The information collected and reported depends upon the client classification. In the case of individuals, the information is as follows:
  • Name in English and Chinese
  • ID issuing country/jurisdiction
  • ID type (Hong Kong ID card, ID card issued by the government authority of relevant country/region, passport, or any other official identity document e.g. driver's license)
  • ID number (number of ID document)
For Institutional investors, the information is as follows:
  • Entity name
  • Other official incorporation documents (IBKR will attempt to us the documents clients provided at the point of account opening, whenever possible).
  • Legal Entity Identifier (if you do not already have an LEI, you can order one through IBKR when requesting trading permissions for China Connect. Note that obtaining a LEI can take up to three days, is associated with an application fee imposed by the LEI issuing organization, and an annual renewal fee thereafter).
Each Northbound trading client will be assigned a Broker-to-Client Assigned Number (BCAN) which will be associated with the identification information collected and will be tagged to every Northbound order on a real-time basis.
 
Who is IBKR authorized to share this information with?
Clients who wish to access the Stock Connect must provide IBKR with consent to provide their information to the Hong Kong Exchanges and Clearing Ltd and the Chinese regulatory bodies such as:
  • Shanghai and Shenzhen Stock Exchanges
  • China Securities Depository and Clearing (Hong Kong) Company Limited
  • Mainland regulatory authorities and law enforcement agencies
 
How will IBKR collect this information?
Clients with existing Northbound trading permissions will be presented with the online form upon log in to Account Management. This form will allow IBKR to collect the required information and consent to submit this information upon order submission.
 
When will the identification take place?
The Northbound Investor ID model will be effective as of October 22, 2018. 
 
Will there be a Southbound Investor ID model?
The SFC and the CSRC also agreed to introduce a similar investor identification regime for Southbound trading as soon as possible after the regime for Northbound trading is implemented.
 
What happens if I do not provide the required information?
Once the Northbound Investor ID model is in effect, clients who either fail to provide the required information or elect not to provide consent to report the required information will not be allowed to submit opening Northbound orders but will be allowed to close existing positions.
 
How can I trade China Connect Stocks?
In order to trade China Connect stocks clients are required to login to Account Management and request the necessary trading permissions in Settings -> Account Settings -> Trading Permissions -> Hong Kong/China Stock Connect.
 
After the trading permission has been requested clients will be prompted with the Northbound Trader Disclosure. Once consent has been given, IBKR will assign a BCAN and send the client file to the HKEX before the deadline at 2:45pm HKT. If the request has been approved, clients will be able to trade on the next day.

Utilization in the Securities Lending Market

Utilization Metrics

Utilization is defined as loaned shares divided by available shares in the securities lending market, expressed as a percentage. The Utilization metric on TWS is not specific to IB. It is based on industrywide data provided by a securities finance data vendor. The metric is not conclusive however, as not every lender reports their Utilization to the vendor. In addition, although the source is believed to be reliable, IBKR does not warrant its accuracy.

Generally, Utilization is the ratio of demand to supply. For example, Apple Inc. (AAPL) may have utilization of less than 1% because the stock has vast availability relative to the demand to borrow shares for shorting. Roku Inc. (ROKU) may have utilization above 90% because of higher demand to short shares as compared to the number of available shares.

For accounts enrolled in the Stock Yield Enhancement Program, a high stock-specific Utilization percentage may increase the likelihood that IB may be able to lend your shares. Conversely, stocks with a low Utilization percentage are generally in lesser demand in the securities finance market, generally reducing IB’s ability to lend your shares.

Utilization can be added as a column in TWS.

Using Mosaic Market Scanner to Determine an Indication of Stock Utilization

TWS users can find stock utilization indications by using Mosaic Market Scanner filters. After opening the scanner, Select Custom Scanner and input parameters. Some useful filters include Price, Market Cap, Fee Rate and Utilization.

Please also see Important Considerations and Risks of Participating in Interactive Brokers Fully-Paid Securities Lending Programs here

 

Overview of T+2 Settlement

Introduction

Effective September 5, 2017, the standard settlement period for securities traded on U.S. and Canadian exchanges will be reduced from 3 business days (T+3) to 2 business days (T+2). Background information regarding this change, its projected impact and a list of FAQs are outlined below.
 
Background
Settlement is a post-trade process whereby legal ownership of securities is transferred from the seller to the purchaser in exchange for payment.  This process is facilitated via a central depository which maintains security ownership records and a clearinghouse which processes the exchange of funds and instructs the depository to transfer ownership of the securities. For U.S. securities, the Depository Trust Company (DTC) operates as the primary depository and the National Securities Clearing Corporation (NSCC), the clearinghouse. The Canadian Depository for Securities (CDS) performs these functions for Canadian securities. The current settlement cycle for both U.S. and Canadian securities is 3 business days following the trade date.
 
Why is the settlement period changing?
Operational efficiencies afforded by registering securities ownership in an electronic form and the ease and low cost by which clients may transfer funds electronically are critical factors enabling the shortening of the settlement cycle. The settlement cycle was last reduced from 5 business days to 3 in 1995 and transactions involving the delivery of physical certificates or payment via check continue to decline.
 
Shortening the settlement cycle is expected to yield the following benefits for the industry and its participants:
 
  • Lessens risk to the financial system – the likelihood that the price of a given security will change increases over time and reducing the settlement day lessens exposure to credit risk due to non-payment or non-delivery of that security. By reducing the notional value of outstanding obligations in the settlement pipeline, the financial sector is better protected from the potential systemic consequences of serious market disruptions. 
  • Cash deployment efficiencies – clients who maintain “Cash” type accounts are subject to restrictions which may preclude them from trading with unsettled funds (i.e., “Free-Riding” or buying and selling a security without paying for it). With T+2, funds from the sale of a security will now be available 1 business day earlier, thereby providing quicker access to funds and the ability to redeploy them sooner for subsequent purchases. 
  • Enhanced global settlement harmonization - the transition to a T+2 settlement cycle will align the U.S. and Canadian markets with other major international markets in Europe and Asia that currently operate in a T+2 environment.
 
What products are impacted by this change?
U.S. and Canadian stocks, ETFs, ADRs, corporate bonds, municipal bonds, CFDs, and unit investment trusts (UITs)
 
How will this change impact my account?
Dividends & corporate actions – securities must be purchased prior to the Ex-Date for entitlement to dividends or other rights associated with the security.    Under the current T+3 settlement cycle, the Ex-Date is typically 2 business days prior to the Record Date and this relationship will be reduced to 1 business day under T+2.
 
Short sale transactions – brokers are required under SEC Rule 204 to close out short sales if unable to borrow securities and make delivery at settlement. Currently, close out must take place by no later than the beginning of regular trading hours on T+4.  With the shortening of the settlement cycle to T+2, close out will be moved up 1 business day to T+3.
 
T+2 Order Destination – IB currently offers an order destination (TPLUS2) which allows covered call writers to purchase and deliver, upon assignment, shares having a more favorable cost basis. This T+2 order, which reduces the possibility of triggering an unwanted capital gains tax, will be amended to T+1 delivery in order to provide the same benefits.  Note that this T+2 order destination will be disabled prior to September 5, 2017 and the T+1 order destination enabled shortly after that date (i.e., there will be a transition period during which this accelerated settlement order destination will not be offered).
 
Option Exercise – The delivery period for stock and payment of cash resulting from the exercise of stock options will be reduced from 3 business days to 2.
 
Interest paid on credit balances – interest computations are based upon settled cash balances. If you purchase stock and have sufficient cash to pay for the purchase in full (i.e., no margin loan), the proceeds necessary to pay for that stock are currently eligible to earn interest up until T+3 at which point they are remitted to the clearinghouse. That interest earning period will be reduced by 1 business day under T+2. Note, however, that when that security is sold the funds settle to your account 1 business day earlier under T+2 and are then eligible to earn interest. 
 
Interest charged on debit balances – interest computations are based upon settled cash balances. If you purchase stock and borrow funds to pay for the purchase (i.e., a margin loan), interest is not charged on the loan until payment is remitted to the clearinghouse on T+3. That loan date will start 1 business day earlier under T+2. Note, however, that when that security is sold, the proceeds are credited to your account and will partially or fully pay of the loan 1 business day earlier under T+2.   
 
FAQs

Will the settlement for purchases and sales of options, futures or futures options contracts change?

No. These products currently settle on T+1 and that settlement cycle will not change.

 
Will the settlement for purchases and sales of mutual funds change?
No. All mutual funds offered by IB currently settle on T+1 and that settlement cycle will not change.
 
Will this change have any impact upon the cash or assets required to initiate an order?
No. All orders are currently pre-checked prior to submission to ensure that the account will be compliant were the order to execute. In the cash of cash accounts, that means that the account must have the necessary settled cash on hand to meet the settlement regardless of T+3 or T+2.  Similarly, in the case of margin accounts, the account must have the necessary Excess Equity to remain margin compliant. This safeguard will not change under T+2.
 
Will this change have any impact upon the timeframe by which securities are transferred via ACATS or ATON?
No. Transfer processes will not be impacted by the move from T+3 to T+2.

U.S. Microcap Stock Restrictions

Introduction
To comply with regulations regarding the sale of unregistered securities and to minimize the manual processing associated with trading shares that are not publicly quoted, IBKR imposes certain restrictions on U.S. Microcap Stocks. A list of those restrictions, along with other FAQs relating to this topic are provided below. 

Microcap Restrictions

  • IBKR will only accept transfers of U.S. Microcap stocks from Eligible Clients. Eligible Clients include accounts that: (1) maintain equity (pre or post-transfer) of at least $5 million or, clients of financial advisors with aggregate assets under management of at least $20 million; and (2) have less than half of their equity in U.S. Microcap stocks.
  • IBKR will only accept transfers1 of blocks of U.S. Microcap stocks where the Eligible Client can confirm the shares were purchased on the open market or registered with the SEC;
  • IBKR will not accept transfers1 of or opening orders for U.S. Microcap Stocks designated by OTC as Caveat Emptor or Grey Market from any client. Clients with existing positions in these stocks may close the positions;
  • Execution-only clients (i.e., execute trades through IBKR, but clear those trades elsewhere) may not trade U.S. Microcap Stocks within their IBKR account. (IBKR may make exceptions for U.S.-registered brokers);


Microcap FAQs

What is a U.S. Microcap Stock?
The term “Microcap Stock” refers to shares (1) traded over the counter or (2) that are listed on Nasdaq and NYSE American that have a market capitalization of between $50 million to $300 million and are trading at or below $5. For purposes of this policy, the term Microcap Stock will include the shares of U.S. public companies which have a market capitalization at or below $50 million, which are sometimes referred to as nanocap stocks or trade on a market generally associated with Microcap Stocks.

As Microcap Stocks are often low-priced, they are commonly referred to as penny stocks. IBKR may make exceptions, including for stocks traded at low prices that recently had a greater market cap. In addition, IBKR will not consider ADRs on non-US companies to be Micro-Cap stocks.


Where do Microcap Stocks trade?
Microcap Stocks typically trade in the OTC market, rather than on a national securities exchange. They are often electronically quoted by market makers on OTC systems such as the OTC Bulletin Board (OTCBB) and the markets administered by the OTC Markets Group (e.g., OTCQX, OTCQB & Pink). Also included in this category are stocks which may not be publicly quoted and which are designated as Caveat Emptor, Other OTC or Grey Market.
In addition, U.S. regulators also consider stocks listed on Nasdaq or NYSE American trading at or below $5 with a market capitalization at or less than $300 million to be Microcap Stocks.

What happens if IBKR receives a transfer from an Eligible Client where one or more of the positions transferred is a Microcap Stock?
If IBKR receives a transfer containing a block of a Microcap stock, IBKR reserves the right to restrict the sale of any Microcap position(s) included in the transfer unless the Eligible Client provides appropriate documentation establishing that the shares were either purchased on the open market (i.e., on a public exchange through another broker) or were registered with the SEC pursuant to an S-1 or similar registration statement.

Eligible Clients can prove that shares were purchased on the open market by providing a brokerage statement or trade confirm from a reputable broker reflecting the purchase of the shares on a public exchange. Eligible Clients can establish that the shares are registered by providing the SEC (Edgar system) File number under which their shares were registered by the company (and any documents necessary to confirm the shares are the ones listed in the registration statement).

NOTE: All customers are free to transfer out any shares we have restricted at any time.
 

What restrictions will IBKR apply to Prime accounts?
Clients whose activities include Prime services are considered Eligible Clients solely for the purposes of those trades which IBKR has agreed to accept from its executing brokers. However, while Prime accounts may clear U.S. Microcap Stocks at IBKR, those shares will be restricted until such time IBKR confirms that the shares are eligible for re-sale under the procedures discussed above.  To remove the restriction for shares purchased on the open market, please provide an official Account Statement or Trade Confirmation from the executing broker or have the executing broker provide a signed letter, on company letterhead, showing the IBKR account name and number, stating that the shares were purchased in the open market, along with the details of the executions (date, time, quantity, symbol, price, and exchange).  Or if the shares were acquired through an offering the letter must provide documents or links to the relevant registration statement and state that the shares were part of it.

To summarize: Sell Long trades will be accepted if the long position is no longer restricted.  Sell Short trades will be accepted.  Buy Long trades will be accepted and the position will be restricted until Compliance is provided with sufficient information to remove the restriction.  Buy Cover trades and intraday round trip trades will not be accepted.

 

What happens if a stock you purchase gets reclassified as Grey Market or Caveat Emptor?
If you purchase a stock in your IBKR account that at a later date becomes classified as a Caveat Emptor or Grey Market stock, you will be allowed to maintain, close or transfer the position but will not be able to increase your position.

 

Where can I find a list of stocks that IBKR has designated as U.S. Microcaps?

A list of stocks designated as U.S. Microcaps by IBKR is available via the following link: www.ibkr.com/download/us_microcaps.csv

Note that this list is updated daily.

Where can I find additional information on Microcap Stocks?
Additional information on Microcap Stocks, including risks associated with such stocks may be found on the SEC website: https://www.sec.gov/reportspubs/investor-publications/investorpubsmicrocapstockhtm.html

For information regarding Canadian stock transfer restrictions, see KB3118
-----------------------------------------------------------
1This includes transfers by any method (e.g., ACATS, DWAC, FOP), conversion of Canadian listings to their U.S. equivalent via “Southbound” transfer, transfers to cover existing short positions, IB Prime customers executing with other brokers and clearing to IBKR, etc.

 

IEX Discretionary Peg Order

Background: 

IEX offers a Discretionary Peg™ (D-Peg™) order type which is a non-displayed order that is priced at either the National Best Bid (NBB for buys) or National Best Offer (NBO for sells). D-Peg™ orders passively rest on the book while seeking to access liquidity at a more aggressive price up to Midpoint of the NBBO, except when IEX determines that the quote is transitioning to less aggressive price

D-Peg™ combines elements of Midpoint Peg, Primary Peg, and traditional discretionary order types.
 
Information about slow and predictable changes in the NBBO are detected in IEX's Crumbling Quote Indicator and provides D-Peg™ orders with an instruction to stop seeking access to liquidity at a more aggressive price until the quote returns to a stable state.

 

How to Place a D-Peg Order

Please note, the IEX D-Peg order type is only available via the TWS version 961 and above. Instructions for entering this order type are outlined below:

Step 1

Enter a symbol and choose a directed quote, selecting IEX as the destination. Right click on the data line and select Trade followed by Order Ticket to open the Order Ticket window.

 

Step 2

Select the REL order type from the Order Type drop down menu.

 

Step 3

Click on the Miscellaneous tab (Misc.) and at the bottom there will be a checkbox for "Discretionary up to limit". Check this box. The price that you set in the Limit Price field will be used at the discretionary price on the order.

 

 

Step 4 

Hit Preview to view the Order Preview window.

 

 

For additional information concerning this order type, please review the following exchange website link: https://www.iextrading.com/trading/dpeg/

 

 

SEC Tick Size Pilot Program

Background

Effective October 3, 2016, securities exchanges registered with the SEC will operate a Tick Size Pilot Program ("Pilot") intended to determine what impact, if any, widening of the minimum price change (i.e., tick size) will have on the trading, liquidity, and market quality of small cap stocks.  The Pilot will last for 2 years and it will include approximately 1,200 securities having a market capitalization of $3 billion or less, average daily trading volume of 1 million shares or less, and a volume weighted average price of at least $2.00.

For purposes of the Pilot, these securities will be organized into groups that will determine a minimum tick size for both quote display and trading purposes. For example, Test Group 1 will consist of securities to be quoted in $0.05 increments and traded in $0.01 increments and Test Group 2 will include securities both quoted and traded in $0.05 increments.  Test Group 3 will include also include securities both quoted and traded in $0.05 increments, but subject to Trade-at rules (more fully explained in the Rule). In addition, there will be a Control Group of securities that will continue to be quoted and traded in increments of $0.01. Details as to the Pilot and securities groupings are available on the FINRA website.

 

Impact to IB Account Holders 

In order to comply with the SEC Rules associated with this Pilot, IB will change the way that it accepts orders in stocks included in the Pilot.  Specifically, starting October 3, 2016 and in accordance with the phase-in schedule, IB will reject the following orders associated with Pilot Securities assigned to Test Groups:

  • Limit orders having an explicit limit that is not entered in an increment of $0.05;
  • Stop or Stop Limit orders having an explicit limit that is not entered in an increment of $0.05; and
     
  • Orders having a price offset that is not entered in an increment of $0.05.  Note that this does not apply to offsets which are percentage based and which therefore allow IB to calculate the permissible nickel increment

 Clients submitting orders via the trading platform that are subject to rejection will receive the following pop-up message:

 

 The following order types will continue to be accepted for Pilot Program Securities:

  • Market orders;
  • Benchmark orders having no impermissible offsets (e.g., VWAP, TVWAP);
  • Pegged orders having no impermissible offsets ;
  • Retail Price Improvement Orders routed to the NASDAQ-BX and NYSE as follows:
    - Test Group 1 in .001

      - Test Group 2 and 3 in .005

     
 

Other Items of Note

  • GTC limit and stop orders entered prior to the start of the Pilot will be adjusted as allowed (e.g., a buy limit order at $5.01 will be adjusted to $5.00 and a sell limit at $5.01 adjusted to $5.05).
  • Clients generating orders via third-party software (e.g., signal provider), order management system, computer to computer interfaces (CTCI) or through the API, should contact their vendor or review their systems to ensure that all systems recognize the Pilot restrictions.
  • Incoming orders to IB that are marked with TSP exception codes from other Broker Dealers will not be acted upon by IB. For example, IB will not accept incoming orders marked with the Retail Investor Order or Trade-At ISO exception codes.
  • The SEC order associated with this Pilot is available via the following link: https://www.sec.gov/rules/sro/nms/2015/34-74892-exa.pdf
  • For a list of Pilot Program related FAQs, please see KB2750

 

Please note that the contents of this article are subject to revision as further regulatory guidance or changes to the Pilot Program are issued.

 

 

Allocation of Partial Fills

Title:

How are executions allocated when an order receives a partial fill because an insufficient quantity is available to complete the allocation of shares/contracts to sub-accounts?

 

Overview:

From time-to-time, one may experience an allocation order which is partially executed and is canceled prior to being completed (i.e. market closes, contract expires, halts due to news, prices move in an unfavorable direction, etc.). In such cases, IB determines which customers (who were originally included in the order group and/or profile) will receive the executed shares/contracts. The methodology used by IB to impartially determine who receives the shares/contacts in the event of a partial fill is described in this article.

 

Background:

Before placing an order CTAs and FAs are given the ability to predetermine the method by which an execution is to be allocated amongst client accounts. They can do so by first creating a group (i.e. ratio/percentage) or profile (i.e. specific amount) wherein a distinct number of shares/contracts are specified per client account (i.e. pre-trade allocation). These amounts can be prearranged based on certain account values including the clients’ Net Liquidation Total, Available Equity, etc., or indicated prior to the order execution using Ratios, Percentages, etc. Each group and/or profile is generally created with the assumption that the order will be executed in full. However, as we will see, this is not always the case. Therefore, we are providing examples that describe and demonstrate the process used to allocate partial executions with pre-defined groups and/or profiles and how the allocations are determined.

Here is the list of allocation methods with brief descriptions about how they work.

·         AvailableEquity
Use sub account’ available equality value as ratio. 

·         NetLiq
Use subaccount’ net liquidation value as ratio

·         EqualQuantity
Same ratio for each account

·         PctChange1:Portion of the allocation logic is in Trader Workstation (the initial calculation of the desired quantities per account).

·         Profile

The ratio is prescribed by the user

·         Inline Profile

The ratio is prescribed by the user.

·         Model1:
Roughly speaking, we use each account NLV in the model as the desired ratio. It is possible to dynamically add (invest) or remove (divest) accounts to/from a model, which can change allocation of the existing orders.

 

 

 

Basic Examples:

Details:

CTA/FA has 3-clients with a predefined profile titled “XYZ commodities” for orders of 50 contracts which (upon execution) are allocated as follows:

Account (A) = 25 contracts

Account (B) = 15 contracts

Account (C) = 10 contracts

 

Example #1:

CTA/FA creates a DAY order to buy 50 Sept 2016 XYZ future contracts and specifies “XYZ commodities” as the predefined allocation profile. Upon transmission at 10 am (ET) the order begins to execute2but in very small portions and over a very long period of time. At 2 pm (ET) the order is canceled prior to being executed in full. As a result, only a portion of the order is filled (i.e., 7 of the 50 contracts are filled or 14%). For each account the system initially allocates by rounding fractional amounts down to whole numbers:

 

Account (A) = 14% of 25 = 3.5 rounded down to 3

Account (B) = 14% of 15 = 2.1 rounded down to 2

Account (C) = 14% of 10 = 1.4 rounded down to 1

 

To Summarize:

A: initially receives 3 contracts, which is 3/25 of desired (fill ratio = 0.12)

B: initially receives 2 contracts, which is 2/15 of desired (fill ratio = 0.134)

C: initially receives 1 contract, which is 1/10 of desired (fill ratio = 0.10)

 

The system then allocates the next (and final) contract to an account with the smallest ratio (i.e. Account C which currently has a ratio of 0.10).

A: final allocation of 3 contracts, which is 3/25 of desired (fill ratio = 0.12)

B: final allocation of 2 contracts, which is 2/15 of desired (fill ratio = 0.134)

C: final allocation of 2 contract, which is 2/10 of desired (fill ratio = 0.20)

The execution(s) received have now been allocated in full.

 

Example #2:

CTA/FA creates a DAY order to buy 50 Sept 2016 XYZ future contracts and specifies “XYZ commodities” as the predefined allocation profile. Upon transmission at 11 am (ET) the order begins to be filled3 but in very small portions and over a very long period of time. At 1 pm (ET) the order is canceled prior being executed in full. As a result, only a portion of the order is executed (i.e., 5 of the 50 contracts are filled or 10%).For each account, the system initially allocates by rounding fractional amounts down to whole numbers:

 

Account (A) = 10% of 25 = 2.5 rounded down to 2

Account (B) = 10% of 15 = 1.5 rounded down to 1

Account (C) = 10% of 10 = 1 (no rounding necessary)

 

To Summarize:

A: initially receives 2 contracts, which is 2/25 of desired (fill ratio = 0.08)

B: initially receives 1 contract, which is 1/15 of desired (fill ratio = 0.067)

C: initially receives 1 contract, which is 1/10 of desired (fill ratio = 0.10)

The system then allocates the next (and final) contract to an account with the smallest ratio (i.e. to Account B which currently has a ratio of 0.067).

A: final allocation of 2 contracts, which is 2/25 of desired (fill ratio = 0.08)

B: final allocation of 2 contracts, which is 2/15 of desired (fill ratio = 0.134)

C: final allocation of 1 contract, which is 1/10 of desired (fill ratio = 0.10)

 

The execution(s) received have now been allocated in full.

Example #3:

CTA/FA creates a DAY order to buy 50 Sept 2016 XYZ future contracts and specifies “XYZ commodities” as the predefined allocation profile. Upon transmission at 11 am (ET) the order begins to be executed2  but in very small portions and over a very long period of time. At 12 pm (ET) the order is canceled prior to being executed in full. As a result, only a portion of the order is filled (i.e., 3 of the 50 contracts are filled or 6%). Normally the system initially allocates by rounding fractional amounts down to whole numbers, however for a fill size of less than 4 shares/contracts, IB first allocates based on the following random allocation methodology.

 

In this case, since the fill size is 3, we skip the rounding fractional amounts down.

 

For the first share/contract, all A, B and C have the same initial fill ratio and fill quantity, so we randomly pick an account and allocate this share/contract. The system randomly chose account A for allocation of the first share/contract.

 

To Summarize3:

A: initially receives 1 contract, which is 1/25 of desired (fill ratio = 0.04)

B: initially receives 0 contracts, which is 0/15 of desired (fill ratio = 0.00)

C: initially receives 0 contracts, which is 0/10 of desired (fill ratio = 0.00)

 

Next, the system will perform a random allocation amongst the remaining accounts (in this case accounts B & C, each with an equal probability) to determine who will receive the next share/contract.

 

The system randomly chose account B for allocation of the second share/contract.

A: 1 contract, which is 1/25 of desired (fill ratio = 0.04)

B: 1 contract, which is 1/15 of desired (fill ratio = 0.067)

C: 0 contracts, which is 0/10 of desired (fill ratio = 0.00)

 

The system then allocates the final [3] share/contract to an account(s) with the smallest ratio (i.e. Account C which currently has a ratio of 0.00).

A: final allocation of 1 contract, which is 1/25 of desired (fill ratio = 0.04)

B: final allocation of 1 contract, which is 1/15 of desired (fill ratio = 0.067)

C: final allocation of 1 contract, which is 1/10 of desired (fill ratio = 0.10)

 

The execution(s) received have now been allocated in full.

 

Available allocation Flags

Besides the allocation methods above, user can choose the following flags, which also influence the allocation:

·         Strict per-account allocation.
For the initially submitted order if one or more subaccounts are rejected by the credit checking, we reject the whole order.

·         “Close positions first”1.This is the default handling mode for all orders which close a position (whether or not they are also opening position on the other side or not). The calculation are slightly different and ensure that we do not start opening position for one account if another account still has a position to close, except in few more complex cases.


Other factor affects allocations:

1)      Mutual Fund: the allocation has two steps. The first execution report is received before market open. We allocate based onMonetaryValue for buy order and MonetaryValueShares for sell order. Later, when second execution report which has the NetAssetValue comes, we do the final allocation based on first allocation report.

2)      Allocate in Lot Size: if a user chooses (thru account config) to prefer whole-lot allocations for stocks, the calculations are more complex and will be described in the next version of this document.

3)      Combo allocation1: we allocate combo trades as a unit, resulting in slightly different calculations.

4)      Long/short split1: applied to orders for stocks, warrants or structured products. When allocating long sell orders, we only allocate to accounts which have long position: resulting in calculations being more complex.

5)      For non-guaranteed smart combo: we do allocation by each leg instead of combo.

6)      In case of trade bust or correction1: the allocations are adjusted using more complex logic.

7)      Account exclusion1: Some subaccounts could be excluded from allocation for the following reasons, no trading permission, employee restriction, broker restriction, RejectIfOpening, prop account restrictions, dynamic size violation, MoneyMarketRules restriction for mutual fund. We do not allocate to excluded accountsand we cancel the order after other accounts are filled. In case of partial restriction (e.g. account is permitted to close but not to open, or account has enough excess liquidity only for a portion of the desired position).

 

 

Footnotes:

1.        Details of these calculations will be included in the next revision of this document.

2.        To continue observing margin in each account on a real-time basis, IB allocates each trade immediately (behind the scenes) however from the CTA and/or FA (or client’s) point of view, the final distribution of the execution at an average price typically occurs when the trade is executed in full, is canceled or at the end of day (whichever happens first).

3.       If no account has a ratio greater than 1.0 or multiple accounts are tied in the final step (i.e. ratio = 0.00), the first step is skipped and allocation of the first share/contract is decided via step two (i.e. random allocation).

 

SEC Tick Size Pilot Program FAQs

Tick Size Pilot ("TSP" or "Pilot") Program:

Under the TSP Program,  if IB receives any order in a Pilot Security that does not conform to the designated pricing increment (e.g., a limit price in a $0.01 increment for a security designated as trading $0.05 increments), IB will REJECT that order, subject to limited exceptions. IB strongly encourages a thorough review of your software or your vendor’s software to understand the criteria for what causes an order in a Pilot Security to be rejected to permit you or your vendor to make changes to correctly handle orders in Test Group Pilot Securities.
 

FREQUENTLY ASKED QUESTIONS:

Q: What is the Tick Size Pilot?
A: On May 6, 2015 the SEC approved an amended TSP NMS Plan. The Pilot will be two years in length. Data collection for the Pilot began on April 4, 2016, 6 months prior to the implementation of the trading and quoting rules for the Pilot. Implementation of the trading and quoting rules for the Pilot will begin on October 3, 2016.

The Pilot will be conducted using a Control Group and three Test Groups where variations in quoting and trading rules exist between each group. Please see the TSP NMS Plan for additional information.

 

Q: Will the Pilot quoting and trading rules apply during regular market hours, pre-market hours and post market hours?
A: The Pilot rules apply during all operational hours (pre-market, regular hours, and post market hours trading).

 

Q: Will the Pilot quoting and trading rules apply to odd-lot and mixed-lot sizes?
A: Yes, the Pilot rules to all order sizes.

 

Q: Will orders in Control Group Securities be accepted in price increments of less than $0.05?
A: Yes, orders submitted in price increments of less than $0.05 will continue to be accepted in Control Group securities.

 

Q: Will orders in a Test Group 1, 2 or 3 Pilot Securities be accepted in price increments of less than $0.05?
A: No, unless covered by an exception, orders submitted in price increments of less than $0.05 will be rejected.

 

Q: Which Pilot Security Orders in Test Groups will Interactive Brokers accept at other than $0.05 increments?
        Midpoint orders with no explicitly stated limit price or impermissible offsets will be accepted
        VWAP orders which do not have an explicitly stated limit price or impermissible offsets will be accepted.
        Interactive Brokers will accept Exchange operated Retail Price Improvement orders as follows:
                  Test Group 1 in $0.001 price increments
                  Test Groups 2 and 3 in $0.005 price increments.

 

Q: Will there be any changes to the Opening / Closing processes on Exchanges?
A: Please refer to each of the exchange rules for details but in general there will be no changes to the Opening / Closing process. All orders entered and eligible to participate in Exchange Opening / Closing Cross will be accepted in increments of $0.05. The Exchanges will begin publishing all quotes in increments of $0.05; however, Net Order Imbalance Indicator prices may be published in increments of $0.025.

 

Q: What will happen to my GTC order that was placed prior to October 3rd in a Pilot Stock that was priced in impermissible tick increments?
A: Interactive Brokers will adjust outstanding limit and stop GTC orders in Pilot stocks in Test Groups that are not in permissible tick increments (e.g., a buy limit order at $5.01 will be adjusted to $5.00 and a sell limit at $5.01 adjusted to $5.05).

 

Q: What will happen to my GTC order placed after October 3rd that was placed and accepted in a nickel tick increment but the Pilot Stock moves from a Test Group to the Control Group which permits non-nickel increments?
A: The GTC order will automatically be able to be revised by the user in non-nickel increments on the date the Pilot stock moves from the Test Group to the Control Group. Similarly, if a stock gets added to Test Group due to a corporate action, IB will cancel the GTC order if it is priced in impermissible increments.

 

Q: Where can I find out more information?

A: See KB2752 or the FINRA website for additional details regarding the Pilot Program: http://www.finra.org/industry/tick-size-pilot-program

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