Virtu CEO Doug Cifu Explains Payment for Order Flow and the Future of HFT

forgot game stuff? Sorry, not not familiar with it. You know, one of the most remarkable things about that whole episode was that, for a brief, glorious moment in time, everyone was talking about market structure and things like payment for order flow, dtc C collateral like that was a discussion that you could actually have in mainstream media and sort of with your average person on the street. Yes, but I mean those conversations were in many cases deeply missing formed.

So it is true that there was a lot of talk about market structure and payment for order flow and the dtc C and all that, and I actually did learn stuff, but there was a lot of noise of people who, like you know, spinning conspiracy theories about all

this stuff hyprequency trading, how it really worked. Um, So hopefully people learn something, But I also suspect a lot of people went away from that whole episode unless they listen to lots of course much less in form Look, I'll take what I can get when it comes to getting people like interested in market structure. But I think you're right. I think probably especially on the payment for order flow subject, because it sounds kind of nefarious. You know,

why would someone pay you for trade order flow? They must want something, they must be doing something with the information. I think it tends to lead to you know, a lot of suspicion. Yeah, I think that term in particular, you nailed it. There's something about that term that like invites a lot of sort of conspiratorial thoughts. Yeah, exactly. And of course we saw that really ramp up during

the game's top drama. We even saw Congress start to you know, they had an inquiry into payment for order flow. The concern is that high frequency traders are somehow profiting off of that order flow in a way that hurts retail investors. And of course Robin Hood uses Citadel as its market maker, so we saw Citadel in the news as well. Citadel is uh one of its market makers. Uh, I think, so, which is something we'll get into. It's

like all these a lot. I mean, I've been sort of like spending the weekend looking at some of these stats that the brokers phase and I have lots of questions about that. Um, so who are what are we going to talk about? How are we going to get into this? Okay, so today we are going deep into the payment for order flow discussion, and we're also going to talk more broadly about what exactly a market maker actually does. We have the perfect person to talk about

all this. We have the CEO of Virtue, Doug Si. Welcome, Duve. Hello, how are you guys doing? Hey, We're good. Thanks. Um, maybe to begin with, we should kind of go straight to the elephant in the room and talk about something very very serious. But what's up with the hot dogs? So on your Twitter account you seem to talk a lot about hot dogs? What's going on? Well, I resent the elephant in the room analogy. I'm a bigger guy

and my Twitter handle is Dougie Large. So, against my better judgment, about ten years ago, I opened a Twitter account and then my partner I bought a hockey team and I started tweeting about hockey. And you know, hockey fans for the most part are favorable, nice people, but then you get to five percent of the keyboard warriors and it started to be abusive towards me. So I stopped tweeting about hockey to said, don't tell I'm talking about And I happen to run, as you say, a

quote unquote high frequency trading firm. And in two thousand fourteen, there was this little book called flash Boys that came out and dark pools and all these nefarious sounding terms, and people started tweeting me like I was a criminal. And I said, okay, well that's not a good topic. I guess I'll stop doing that. And then I found the one universal in this country that nobody can say

anything negative about. It's the great American hot dog. And there's a company called Feltman's which is founded by two great veterans from West Point, and they rediscovered the original cone Allan hot dog and they're fantastic. They've got the perfect mix of spices and they kind of pop when you eat them. And I decided, Okay, if I get behind these guys, I have no financial interest. I just love them. They're great Americans and they have a great hot dog. I said, there's not a chance people can

give me grief about tweeting about hot dogs. And you know, I have not had any negative comments. These these look really good. I'm on their website right now, and I'm definitely going to mustard get the mustard. Also, trust me, when I tied the mustard better than like a sell, I put it on everything. I put on everything. I'm definitely gonna order or something. I know market making. I know market making and eating. Those are the two things

I'm an expert in. Maybe we should also talk about market making though, if you insist, So what is H two? So I just give us the sort of brief version of its history and what how it fits into the sort of market ecosystem. Sure, sure, So we started in two thousand eight, Beril even or not. My partner was an old school market maker. He was in the pits, you know those trading pits, remember the movie Trading Places of the New York of the New York Mercantile Exchange.

His name was Vinny Viola. He was an old school market maker. Stood in the middle of the pit and a bunch of guys screamed orders at him, and he tried to make what is known as the bid offer, spread the difference between what a willing buyer and a willing seller we're willing to pay. In that in that pit, he was trading mostly like crude and gasoline futures, right,

So he was a futures trader. And Vinny was smart enough to realize that two odd guys standing in a circular pit screaming at each other making funny hand signals wasn't not going to be the end state of financial intermediation, price discovery, trading, whatever you want to call it, and that technology was going to evolve that process. And so that was his thought behind forming Virtue Financial. I was a lawyer, very happily at a l offer him in

Manhattan called Paul Weis. For eighteen years I was his lawyer, and he said said to me one day, you know you'd be a hell of a businessman. Do you ever think about quitting being a lawyer? I said, not until now, and then I quit and we started Virtue and our idea was to be a very large scaled, automated financial intermediary market making firm that would try to be the best bid and the best offer in every electronic marketplace

in the world. We had a very ambitious goal and obviously we're we're more well known as you guys indicated in your lead in for US equities and being a what's called a wholesale market maker, but we make markets in over two d and fifty different marketplaces in the world, in global equities, but also in f X, and in treasury futures, and in commodity products and medals and corn, sugar, cocoa, you name a product that is trade electronically in a

venue in the world. Frankly, where there's enough need for liquidity, provider a market maker, and that's what Virtue does. And we also, through an acquisition, have a very large agency business where we act as an agent for clients that want to access generally the global equities market. So it's

a pretty large scaled global financial services firm. On the CEO of it, we've got about a thousand employees twelve offices around the world and last year we generated about two point three billion dollars of net trading revenue and that equated to roughly about a billion six five of of IBADA so adjusted EBADA. So we're pretty large financial services firm. That's what we do. Not bad. Yeah, I think your stock is up quite a lot as well. And you're the only publicly traded market maker over in

the US, so you have that distinction too. That is correct. Just on the market making business. Could you maybe talk to us a little bit more about that. I think we throw this term around quite a lot, like, oh, they make markets and whatever, But can you talk to us about what exactly that entails and why don't we narrow it down to US equities? Yeah? Sure, so in US equities, think of it. There's two forms of market making,

if you will, that we engage in. So right now, believe it or not, there are fifteen national securities exchanges. You you probably know NASDAC in New York, but there's another thirteen i E actually may have heard of. Maybe you've heard of the cbo E Stock Exchange. But then there's you know a ten or other ones, including the Members Exchange, which I helped start at Virtue, you know those kinds of things. And so we are a firm that does not really care about directional risk. In other words,

we're not a hedge fund. We're not speculating. We're not buying Tesla at at six hundred hoping it goes to eight hundred. Really, what we're trying to do is be the guy that's on the inside that's willing to buy from you and sell to you, right and sell to somebody else to try to make that little penny spread

every single time. So are holding time in most of the top five names of US equities you know will be hopefully a few seconds or less than a second, right, because the likelihood that a willing buyer and a willing seller come together at exactly the same moment in time is pretty diminimous. It's sort of like if you think about the Civil War, the Revolution I wore two bullets meeting in the middle of the air. It doesn't happen

all that often. So you need a company that is willing enable, has the financial resources, but also understands those The US equities market, with fifteen national securities exchanges and forty different dark pools and a bunch of other brokers, it's a very fragmented market. So stitching together that marketplace takes a lot of financial technology and a lot of investment.

We invest hundreds of millions of dollars every year to have technology that's able to understand and stitch that marketplace together. But again, the difference between what we do and when a lot of other other firms do, like quote unquote high frequency trading firms, is that we are a passive market maker. We're always entering the market by saying, here

we go. We're willing to sell you something at ten, we're willing to buy it at nine, and there's a penny spread in between, and we hope to collect that. More often than not, a lot of times we get run over and we lose money. You mentioned game stop before. I'm sure we'll talk about that plenty. But in the game stop situation, when the markets just crashing one way or together, the market maker pretty much gets its face ripped off right. It's on the train tracks, the trains coming,

and it can't get out of the way. The other thing we do, which I'm sure you want to talk a lot about, is what we call whole selling. So there are these institutions called retail brokers, wealth managers. You know robin Hood, Fidelity, Schwab e Trade which is now Morgan Stanley, but also Stifle, Raymond, James, JP, Morgan Asset Management, RBC Wealth Management. Think of any aggregator of high net

worth or professional trading flow. In the United States. We have this unique structure that those institutions have a choice. They can send their orders, their market orders right to either in exchange to a dark pool, or they can send it to a whole sell or a market maker. Citadel is the largest retail market maker. We're number two.

They've got roughly the market we've got roughly. And then there's a handful of other institutions, Susquehanna too, Sigma Ubs, We're all competing for that order flow from roughly two hundred retail brokers, wealth managements, wealth managers, excuse me, aggregators of flow, etcetera. So you just named a bunch of market makers that you compete with, and I'm wondering, when it comes to something like market making, it sounds like

such a basic function. You know, you're matching up buyers with sellers and you're taking a small cut of the transaction. What is competing or what does competition actually look like in that scenario? Like what what makes Virtuo special or different to say Citadel or Susquehanna. Yeah, that's a great question.

So I should have actually, uh explained that better. So let's go back to the two hundred institutions we we we that I mentioned before, right, everybody from a Merror trade to Zecho Trade eight Z and everybody in between. Every single one of those institutions has the best Best Execution committee, And what they're measuring is there's something called a national best bid and best offers. So that's the

consolidated tape. You take those fifteen national securities exchanges and you say, okay, at any moment in time, right, for at least a hundred shairs, what's the what's the best price that someone is willing to sell in the best price that someone is willing to buy a particular security. That's called the n b B Okay. And so every one of those retail brokers gets the same feed, right, the same consolidated feed that we do, right, and they all measuring at the time that they send us a

market order. Right, you want to buy a hundred shares of Tesla, what was the national best offer for Tesla at that moment in time? Okay. What we do as marketmakers is we try to improve that national best bid

or best offer. That's called price improvement or e Q. And as you mentioned in your in your lead in, all of the statistics around price improvement are publicly available, and so the brokers have their own routing statistics where they measure our execution quality, the ability for the market maker to improve off of the n b b O and to the extent and to the amount we're willing to do so, they will send us order flow. Now, obviously they don't send their order flow to Citadel or

two vertuur to Susquehanna. But and they don't do it all as one big bucket. Sometimes they do it by different names, depending upon a DV, depending upon volume. They all have their own unique routing methodologies. But every single one of them is based off the the amount that the market maker is willing and able to improve the

national best bid and best offer. Just to give you some statistic which is pretty compelling, in two thousand and twenty, the five or six of us the market making firms in the aggregate provided price improvement, So prices better than the n b b O in an aggregate amount of three point seven billion dollars. Right, So that means a retail investor in general, right, is getting a price that is better than what they could get on a national securities exchange. Right. And so that's the that's why they

rout us those orders. Right. Payment for wonder face a separate thing. We'll talk about that in a second. But two d Odd Brokers are saying, hey, you can provide better execution quality than we can get on an exchange. And the natural question you're about to ask me is why would you like to ask that question? You want me to just keep going. I just want to back up real quickly. I just want one I got. I got on a roll sometimes and I talked forever, so I'll try to stop for you. Guys. This is great.

It's our job to stop you, but this is super helpful. I just one. So the NBBO it's purely exchange price correct because that's the only the difference between exchange and a dark pool. Right. You know, the marketplace is terrible at naming things, right, A dark pool sounds like this nefarious thing, and also it's a flash trade. I know, if I could do my life over again, I would

have renamed all these things. But putting that aside, virtue is named for virtue, right, we try to be virtuous to the market, so we at least have a nice name. So what a dark pool is? It's actually technically it's called an a t S or an alternative trading system,

the lynchpin of the U S equities market. And indeed, you know, the U S economy is competition, right, and so a long time ago, back when I was a lawyer, if someone said, you know what these exchanges and it was really just the New York Stock Exchange until let's say the early nineties. They have a monopoly, they're really expensive. Bad things go on there. There was you know, alleged criminal activity with the specialist. You can google all that.

So the exchanges weren't all that, let's put it that way, right, and they were, you know, it was kind of a private boys club, if you will. And so a bunch of banks and other broker said, we want to be able to create an alternative trading system and a t S. So the SEC has REGGAETS and it basically says, if you want to be a place where people are sending orders, right, as long as you don't have more than five of the market in a particular name, you can do that.

You have to publish your rules. We run to a t S is at Virtue. You've got to publish your rules, but you cannot display market data. Okay, so it has to be quote unquote dark. That's why people call them dark pools. So people brokers right can rest orders in an A T S with the safety and security that they know that that they're not exposing large size to the rest of the world. Why don't people like to trade on exchanges is because the entire world knows, Like

you know, I'm an agency broker. If I get in order from a large asset manager to buy a hundred thousand shares a Tesla and I just post that on an exchange. Now the entire world knows that there's a giant whale out there that wants to buy a hundred thousand shares a tesla. What's going to happen to the market? Right? You can imagine people will change the risk that they see in that market because they know that there's a

huge imbalance, right. And so that's one of the reasons why investors, broker a smart folks in the marketplace wanted choices, and that's why they created these A T s s. Right. So, an exchange has public displayed market data, right, it gets quoting revenue because of that they make it. They make about four or five million dollars a year justin consolidated

tape revenue. That's one of the benefits to being exchange, right, Whereas an a TS is only charging a transaction fee, right, and orders etcetera are executed quote unquote in the dark, and that's why people call them dark pools. There's nothing to various about them. It's just an alternative method. Again, always think what what the great thing about our marketplace in the US and why it's it's so darn efficient and why it's so damn competitive and cheap is because

you have this competition. So I want to esca follow up. You know, all of the I was doing a little trying to learn a little bit to prepare for the for this discussion. And so I see all of the brokerages are the retail brokerages or I guess everyone follows

the six files, these Form six or six. We're they talk about the market makers to whom they're routing orders and they helpfully sort of like basically break down their market share and so for eat, So for example, robin Hood in the last quarter, it looked like almost their shares went through Citadel Virtue looks like got a little bit under. What determines how a broker allocates its routing is it is every trade its own discrete auction of and you're all competing for it. There like, how does

this process work? No, not at all, not at all. So the way it works is, as I try to articulate, they have a best execution committee, right, and they have their routing protocol. Again, it's always based off of how much are we willing to improve off of that m B B oh so quote unquote price improvement um. And so in the beginning of the month. Quarter some brokers do it weekly, but it's not daily, and it's certainly not by symbol, right, there's just way too many orders

for every thing to be an individual auction. So they said it in the beginning of the week. Let's say at the beginning of the month. Every broker's got their own rule and they say, okay, in the prior period, right, so it's you know, we're now in March. So in February, Virtue, Citadel, Susquehanna too, Sigma. I don't know who else is in you know, Ubs, Wolverine right there, five or six firms we all bashed, we bashed our heads against you know, each other, and for you know, every broker's got a

different way of looking at it. But for the top five hundred names that are in the snph. Here's the aggrega amount of price improvement. And Citadel came in first place, right because they provided forty two points of EQ. It's all measured off of the mid of the mid So how much are you willing to improve off of the midpoint between the bid and the offer? And Virtue came

in second place, Susquehanna third, two sigma, etcetera. So this therefore, in the month of March, right, we're gonna give Citadel for Virtue Susquehanna twelve percent, etcetera. During the measurement period, whether it's a eeker a month, we're in constant dialogue with them. They will say, hey, look, you're doing really well in the top five indet names, but you're really doing poorly in the bottom thousand names. Can you improve

your EQ? So they're always, you know, trying to get us to frankly, provide more value back to their their clients. And if you watch TV, and I'm not going to name the network because it's a competing network, there's actually one of the really really large brokers. There's two dudes sitting having lunch and one guy shows him his little iPhone and says, well, you know, look at the execution quality I got, and he buys, and he saved twelve dollars and ninety three cents, and he pays for the

grill cheese sandwich at lunch. Right, they must be in like not in New York because the grill cheese would cost more. But that that's is literally that's what we do, right, So think about how important it is that an advertising agency for one of the largest retail brokers in the world. Right, that's an American institution. I'm not going to name their name. You can think of the commercial right, they are spending money advertising the word that Citadel, virtue, sus behind, etcetera.

Do I think about how ingrained that is in the system, and then juxtaposed that against the frankly lunacy that people were articulating about Robin Hood and Citadel. It's just, you know, that's why I watched Late January and my my job was like hitting the table and thinking, my god, these people have no idea what the hell they're talking about. You know, it's such an important part of the ecosystem, and it's so ingrained, and it's so valuable that one

of the largest American financial institutions. You think so much of it that it advertised it that this as as like a service, right. I apologize for my voice changing there, but it's like the the the juxtaposition of the two was just so amazing. Here I am watching, you know, the anchors on that network who don't have a clue what the hell they're talking about. If you follow my Twitter account, I actually tweeted one of them and told him that, and then he had me on the I

saw you you tweeted your personal phone number. That seemed kind of risky. Well not really, you know, I got not and a hide and he was so naive. I'll be nice about what he was saying. It was it was embarrassing, I thought, and I told him as much. Anyhow, so I will get off my soapbox and allow you to continue. Well, so why don't we get over to the GameStop phenomenon, and maybe just to begin, I'll ask

a sort of broad question. So how much did the shift to a no commission trading model and the sort of boom in retail stock trading that we've seen over the past year, Like, how much of a difference did that make for your business? Yeah? Look, I mean, it was huge. I mean, and again thank you for noting it really was the zero commission phenomena and that that

was a long time coming. Right. There was a whole bunch of regulatory changes in two thousand five, you know, decimalization, right, so spreads narrowed, technological advances, you know, give a lot of give a shout out to all of the pioneers and guys that started a merry trade and e trade in etcetera, etcetera. Um Robin Hood, Uh, you know, was

the zero commission broker. I believe they started I think in two thousand fifteen, and I knew at some point the incumbents, obviously you know, Schwab, Fidelity, E Trade, etcetera, would have to match that pricing, and they did and that happened in November two right. So that was like sort of the the Kuda gra of a long period of technology and evolution, you know. And then on top of that, you know, the pandemic hits right, work from home.

You know, there's no sports betting, you know what, the Tesla. There's a whole bunch of other factors right that led into it. It really was a zero commission phenomenon. So if you think about retail trading as the percentage of the US equities market, it went from called it like fifteen percent. Two is high on some days as like, So that is a meaningful increase. It's kind of settled somewhere between twenty two and of the overall US equity market.

But this is a very important and as was demonstrated in late January, a powerful segment of the marketplace, and so it needs to be understood and reckoned with and the regulators obviously we'll look at all this, but at the end of the day, you've seen a systemic shift in the US equity market. I will say, because we're a global market maker, this is not unprecedented. You know, if you travel over to Japan, where we have we

do a lot of business. You know, we have a partnership with SBI Securities where we do something similar in terms of being a retail market maker, and over there, you know, retail is a big part of market. You know that people have their smartphones and they're trading all the time, and not just equities. I mean they're trading again futures they trade, you know, the SMP futures, they trade, the Russell you know. So this this shift is important

and systemic, but it's not without global precedent. Can we go back you you mentioned the term payment for order flow, and it's scary and people don't understand it. It is an ominous sounding term andent. But I do think it's like one of the things in this whole game Stop story that people got super confused about. Why would you pay for order flow? What? What is it so value about about my five tesla trade on robin note that you'd pay for it? Yeah, exactly, We're waiting for your trade,

just tell me when it's coming. So let let me take a step back. So before I mentioned there were two hundred odd retail brokers, wealth managers, etcetera. Right, and those are our clients, and Citadel's got you know, a similar bunch. It's not just US institutions, by the way, there's Canadian and European wealth managers. They're sending us orders and getting guaranteed execution along the eCos you know, in

the ecosystem I described to you earlier. So of that two hundred eye brokers, there's roughly ten that's say, okay, in addition, in addition, that's the key to price improvement. We want you to pay us a rebate, okay, and so effectively, and that rebate is going to be set. There's not an auction right there, not routing flow because Citadel is willing to pay a couple of pennies more than virt two. It's set and it's in stone. So

there are some brokers. Let's say give us ten mills, right, ten ten cents per d. I don't want to be two technical. Others say eighteen per hundred, whatever it is, And that goes into our calculation of how much value are we willing to provide back to the broker from our perspective, from the virtual perspective, I imagine City on the other competitors look at it the same way. We're Switzerland. There is value to us as the market maker in

extracting the bidden offer. Really, what we're doing is, you know, if Tesla is a nickel wide in the marketplace, we think we can narrow that spread, maybe by a halfpenny, maybe by a penny. Right, because we're really good, and we're really good, We've invested a lot of money in it. And because your order and literally the hundreds of thousands of other orders that we're getting are smaller in size,

so they're not going to move the marketplace. Right, they're not big institutional orders, and they tend emphasis on the tend not to be correlated with the remainder of the marketplace. Right, because the theory is, Hey, Joe is a retail investor. He's gonna trade five times a day, five times a month, whatever it is. He's going to buy his hundred shares.

He's gonna push his little button. He's gonna want to buy a market buy a hundred shares of Tesla at the market, and he's gonna hold it for six months, a year, three months, and whether he buys it at you know, ten, or we're gonna slightly price improvement, Joe doesn't really care, but we care a lot. So you're not competing with Virtue in Citadel, right. Virtue in Citadel have this unique ability to narrow the bid offer spread and extract some value. Right. Joe has a very different time,

you know, a temporal view of the world. Joe's thinking, all right, I'm going to hold this thing for a week, a month, whatever it is. We're trying to hold it literally for you know, if we can ten milliseconds a second because it's gonna be thrown into this portfolio that we're managing, and we're gonna try to extract that bid offer.

And really, what the brokers have done, they're smart. They realize there's value two smaller non correlated markets, two orders, excuse me, and they've gone to the market makers over the last thirty years. This is not a new phenomenon. Said listen. We know you guys are good, We know you guys can make money off this. We know that this money means, this value is only there for the

market makers. It's not there for anybody else. We're not taking money from a retail investor, but we the retail brokers, we want you to pay profit share some of that bid offer back to us, and for the most part, we're gonna return that to our clients in the form of price improvement the ad I mentioned before right there.

And in some cases the brokers have made a decision which I don't care about, that they're going to take that money and they're gonna use it to offset their costs of providing their service so that they can provide that service back to their clients for zero commission. Right, So think about it this way and then I'll stop my my diet tribe, which is Joe is a retail

and Tesla is offered on the market at ten. We're willing to say, all right, Joe, we're gonna give it to you a nine spot nine nine, so we're actually gonna price improve it. So Joe is happy he bought it actually at a better price than when he saw it in exchange. The reason we're willing to do that is because we think we can make maybe there was a nickel, we can make maybe half a penny. So Joe gets price improvement, virtue makes a little bit of money,

and Joe pays literally zero. The alternative would be, if there's not payment for the flow, Robin Hood's gonna charge you four dollars you portrayed. So you bought a hundred shares and maybe we made half a penny and you've

got a penny of price improvement. You're not buying that Tesla at ten because you think it's gonna go to ten oh one and you're gonna sell it and you're gonna make you know, a dollar, right, You're buying it a ten because you think it's gonna go to you know, thirty and you're gonna make twenty So where the critics are just completely asked backwards. Is there there's no value that I'm taking out of your pocket. I'm taking value out of the marketplace and in fact then profit sharing

it back to you. It's a win win for everybody. The last point I'll make and then I promise i'll shut up, is And the reason I got so piste off at Sorkin was because he sits there every time he says, well, it's like Facebook, there's an information avenge. We're getting client information, complete and utter bullshit. Am I allowed to say that on this It's complete, utter bullshit. Sorkin is wrong about that. I told him that. I'll say it publicly, round and round again. This is not Facebook.

If anything. You know, there's six or seven firms competing. Every single one of the orders we get, we get millions of them per day, are anonymous. We have no idea if it's Joe Sally or if it's some institution behind it. Right, So, the notion that there's some big, nefarious Facebook thing going on here is just you know, a concoction of people that spend way too much time looking at Silicon Valley companies. This is completely opposite. If anything,

the information asymmetry is the opposite way. We have no idea if everybody's going to send us a hunt with chairs to buy Tesla at the same time, and we're gonna get our faces ripped off, and we have no way of knowing that. We don't have a clue. So this is something I actually wanted to ask you. So you mentioned this idea that retail orders tend to be uncorrelated with the wider market, and that makes them attractive

for various reasons. So what happens when you do get a situation like game stop where suddenly everyone is piling in in one direction, we lose millions of dollars. I sit in my office and I'm sitting there grabbing the you know, my table, and my knuckles are turning red on the on whatever it was, January, whatever it was, I forgot that day. When the market rips in one direction and there's limit up, limit down. I mean, it doesn't always happen. Sometimes we get lucky because we're not

flat at all, right. We can be long or short, all right, So sometimes we get lucky. More often than not, you do not get lucky and you get your faces ripped off and we lose millions of dollars. Now, uh, you know that's why we trade eight thousand names. That's why we have a big firm that does a lot of other things. This business is not profitable every day

retail market making. It's not the critics think we just sit there and we collect the spread between Joe and Sally and we collect pennies like we're a toll toll bridge. If that was the case, then literally dozens of other institutions would come in. When industry critics say, oh, this is an easy business. You know what I say, compete, compete, there's no barriered entry here. Get yourself. You know, some investors spend hundreds of millions of dollars in technology, like

we have developed the relationships and compete. This is a very sharp elbowed, difficult business. And when the market rips in one direction in a particular name, more often than not, we lose money. And there are days where I sit in my office and we can be down significant eight figure amounts. That's like tens of millions of dollars right

for time periods. More often than not, it reverts, and we've learned over the years, and this business predates me and Virtue because we bought it from a firm called Night Capital that over twenty years, right, it tends to make more money than not. But it is not an easy business and the market maker has zero, zero informational advantage.

That's the thing that really pissed me off about when Sorkin was talking, because he made it out like there was some informational asymmetry for the market maker, and it's exact exactly the opposite. We have no clue when the Redded Army is going to strike. How the how would we know? But on the other hand, eventually at least robin Hood and some of the other online brokerages did

start to curb trading in Game Stop. So setting aside the informational asymmetry that gave rise to concerns, and as you just said, when you have extreme and extreme weird situations like in game Stub, you start to lose money and then suddenly, you know, the the traded curbs kick in. So doesn't that invite questions about, oh, well, we're these curbs put in plays because you were losing money? Sure

of course. Now I mean, look overall, we're making money during that time period, right, and we we didn't have any conversations with Robin, who had ordered citadel Ken Griffin is a once in a lifetime you know, a business builder, entrepreneur. He's he's extremely ethical. Right, There's not a chance in the world he would risk his billions dollar empire, you know, to have some kind of conversation with with Robin. I knew immediately immediately. I don't want to like sound like

the guy. I mean, we are a self clearing broker dealer. We know the folks of the DTC very well. We know how the margin rules work. I understand the plumbing of Wall Street, so I knew immediately what their issue was and that they had had a huge margin call. Could the public relations and the explanation of that been better, Yeah, of course. I'm sure if Lad could go back and redo his life, and he's an incredibly talented guy, he probably would have, you know, been more direct or more

a little more transparent. But you know, it's not an easy thing to explain how margining works in this country. I'm happy to do it. I'll put you guys to sleep. I know it very well because I started this firm and it was my money making the margin calls, right, So when it's your own money, you tend to really know the rules pretty well. But they got one sided game stop because that's where their clients were buying or selling.

It's an enormously volatile security, and so the rules of the DTC technically the n SCC are that the variation margins of the variation at risk of our margin if you will, for that name, is going to be. So when they had clients literally buying billions of dollars, right, they're gonna get margin, and the rules do not allow you to use customer funds to meet that margin call. Right. So this was literally, as he said, a five or

six sigma once in a generation kind of event that happened. Really, it was the rules of Wall Street that really slowed this thing down. So the system worked exceptionally well. We were in constant communication with the n s c C because we wanted to make sure that we could trade with Robin Hood. Right, there are a counterparty of ours, we take risk, and so the n SCC did a brilliant job in risk managing what was otherwise the situation

that was, you know, getting out of control. Right. They didn't do it for any nefarious reason other than to mitigate risk in the system, because you had a broker that had gotten a little over at ski tips. Right. Once they did that, obviously, Robin Hood raised an unbelievable amount of money. So there's some really smart people that believe in the business model. I I applaud that, and Robin Hood did the only thing they could do, which

was de risk their portfolio and reduced their margin. I would have done the exact same thing where I in the in their situation, I would have done a much much better job, I would think explaining it because I know these rules exceptionally well. So since we're on the topic of you know what people think might be nefarious behavior.

You talked about this idea of information a symmetry. One other criticism that I've seen, or that people sometimes bring up, is the idea that retail trades are somehow treated differently to large institutional trades. Can you talk a little bit about that, Like, what does sitution actually look like? They are? They get much better, they get much better execution. That's the irony of this thing, right, we we have both sides of the business. Okay, So I'll give you an example.

I'll use a couple of names. You know, these are public companies, right or they're large, So Fidelity and Vanguard our giant companies. Right. They both have retail arms and they have institutional arms. Right. Fidelity has got an asset management business, got a retail business. Vanguards the same. They're both great clients of the of ours. I love them dearly. We have fantastic relationships with both them. I literally have been to visit both of them, and the retail and

the institutional business our clients. And they're in different buildings, right, And I literally we get orders from the institutional side, and they're paying us, right, something less than a penny to share, but more than zero. They can't tell you exactly how much to route orders of Tesla, and the notional size of that order, and the way we trade it is really not much different than what we do

in the retail outside. On the retail side, we get paid and and and let me go back to institutional order. We're not We're measured not whether we can provide them the n B b OH, but whether over the course of a day, what the impact of their order is on the marketplace. So as long as we beat a certain benchmark, right, they're happy they haven't moved the market too much with their order. Right. So that's kind of institutional trading. One on one. We're getting paid a commission.

We're acting as an agent. We use our order routing skills and our financial technology in order to route those orders uh as adroitly as we possibly can to minimize impact to not move the n b B out too much. Right now, you go to the retail side, and what the federal securities laws say is that every order that is retail attested from a broker that is less than nine listen to this, nine thou shares is eligible for those six or six reports. So literally, I can get

a thousand share order of Tesla. I don't know what the hell Tesla is at right now. It's let's say it's seven hundred, right, So can do the math. That's

a large order, right. That order comes into the retail through the retail pipes that we have, and as soon as it hits our environment, regardless of what the n b B O is in terms of size, that hundred thousand share order or five thousand share order, it gets measured and we price it off of the n b BA. So even if there's only a hundred shares right at the inside, I'm being very technical right now, where not only are we price improving that, we're size improving it.

And in some instances, like you know, for robin Hood, we're actually paying for the privilege of doing that. And there's some other brokers that take payment forward to flow that are very large. Right, So think about that juxtaposition.

You've got a retail tested order that is, you know, could be hundreds of thousands of dollars that's getting guaranteed execution at or better than what they could get in exchange, and and sometimes they're getting price improvement and the brokers getting paid for it, whereas an institutional order we're getting aid by the broker. Now, look, I'm not screaming poverty. For the most part, the orders aren't that size, right.

But if you if you talk to any institutional investor that is I would say balanced and even killed about how they explain themselves, right, they will say that retail investors have an amazing deal in this country. They would love to be able to do that. Their jobs would be so much easier. The institutional traders all they would be doing would say here you go, virtue sit it will take these orders it Unfortunately, it doesn't work that way.

So the ecosystem in the United States, where you can get literally for no money, a guaranteed fill of a price that you see on your smartphone or better, is by far the best ecosystem in the world. Where in every marketplace in Europe and in Asia, and there's not a market structure that is as beneficial to retail investors

as the United States. That's why I get so like frustrated when I see you know, folks on on that other network, you know, sitting there like mixing metaphors and and cast gating, you know, an ecosystem that they have no clue about. They don't have it, they don't even understand. I mean Stork and sitting there talking about his grandmother.

And I went on TV and said, yeah, your grandmother can hold up her smartphone, and then he talked about his grandmother, not me, And for no money can get a price that's better than what t ro price can get. What the hell are you complaining about. I want to go back to the competition that you guys are in with the Citadels of the world or the two sigmas and so forth. So what are the determinants of who

can deliver better price? So I assume like technology is a factor, your capital probably presumably, let's do I don't know, take risks here and there be willing to extend a better offer speed, Like what do you guys uh competing on? And why is the market such that one firm doesn't just swallow the whole thing by building up sur multiple edge?

Why is it always competition? Yeah? What I what I would say is it's not in The brokers don't want there to be a monopoly, right, So there's sort of like a natural cap if you will, that any one of us has over market share. If you look at if you go through all those six or six reports, Yeah, I mean maybe with some with some small exceptions, you're never gonna see anybody really north of certainly when it comes to marketable orders maybe non marketable limit orders, it

might be higher. But so the brokers naturally right, What would you do if you needed vendors, right, and you could have people bash their heads together, You'd like to keep two, three, and sometimes four or five of us in competition. You want to give us enough that we can be profitable, right, and we can make the investments in technology, and I'll come back to why we make money. But you don't want to be you know, dependent on

a single provider, right, So they want competition. So that's why when analysts research analyst asked me about market share, I said, well, it's really overcooked because there's a natural cap. Really, the way we make money is look, look. And again this predated virtues. So there was a firm called Night Capital that actually kind of helped create this ecosystem. It was called night because it was the Knights of the

round Table. They got all the retail brokers around a table and said, hey, you guys are mad as hell at the New York Stock Exchange. Essentially, why don't you send your orders to us? And that was you know, the genius of the pioneers of of Night Capital. And so, starting you know, twenty years ago, they built a simulation environment of research environment obviously that we now run. That

cost us a lot of money. We've got very sophisticated algorithms and and strategies right that that can internalize that order flow and hopefully more often than not make money on it. We've got you know, dozens and dozens of really really smart men and women you know, that have PhD these and things that I vaguely understand. I'm a liberal arts guy, right, so this is not my area

of expertise. That literally spent you know, thousands and thousands of people hours every year trying to be better at UM And you know what I what I'm good at, what Virtue is good at is we run a very very lean, efficient environment. So yeah, we trade an awful lot, but we're not a big bank, right, So we have less than a thousand employees and we have a very large scale business that's in over two hundred and fifty marketplaces.

So what's our competitive advantage. It's we've got great relationships. We provide great service to those retail brokers, right, because it's a guaranteed execution. If we f up and the market data is wrong, or if we have like you know, the power goes out in our data center something like that, it's still our execution. We got it, we eat it, right, So if we have a mistake, we eat it. Exchanges

can't do that. So it's a service we're providing. And as I said, we've been doing this for a long time and invested a lot of money, and we do it really really efficiently. So if you think of about like what's the margin on this, like the margin on an individual basis, like on a single name is literally single digits and subpenny And why are we so profitable and why is this business work? Again? It comes back

to scale, right. We we trade twenty five thousand different financial instruments and if we you know, we try to make a couple hundred bucks, a thousand bucks on them, that kind of thing, and it adds up over the course of a day. And this is a very you know, scale business, which is why it's very difficult. You know, you didn't notice, uh in the names of competitors Goldman Sachs or JP Morgan or Barkley's or Morgan Stanley, Right, they all used to do this business right there, but

they had to get out of it. If you go look at the list like UBS is in the business, they're probably like number four or five, and they're kind of, you know, not as competitive frankly, because it's really hard to do this business. If you've got a huge global institution, you've gotta feed. You know, someday I'll invite you to my office when the pandemics over. It's not that pretty right. We don't spend money on the on you know that

kind of thing. We have to spend money on the research environment and the simulation environment and and so that's why this business works for these kinds of firms. And Citadel is by far, you know, our biggest competitor, and they're fantastic at it. And you know, the notion that somehow, you know, they were mixed up in this robin hood, you know, a conspiracy theory, was just beyond comical to me.

So I mentioned in the intro that one of the big things about game Stop and robin hood was that it kind of thrust this issue into the spotlight, which you know can be a bad thing. And we did see politicians and d C take a sudden interest in payment for order flow. What's your read on how they are thinking about it at the moment and would you expect them to crack down in some way on the business.

And actually, can I just add on, so in the UK they don't have payment for order flow um as far as I can member, I think they banned it. So why has the US gone ahead with this? But other jurisdictions have you know, there's something about the model that has turned them off. So why is that? Yeah, what I would say is, look, I mean this is not like some new Obviously people acted like as this

there was you know, a new situation. Right, this has been you know, this structure, this ecosystem has been going on for thirty plus years. To answer the first part of your question, which is, you know, the SEC has looked at this five or six times, the whole notion of wholesaling and and payment for order flower rebates, The SEC and Finraum are always examining the best execution statistics and obligations of all the retail brokers from Robin Hood to you know, z Echo Trade, and of all the

market makers from Virtue, Cita, etcetera. Right, So this is not like an area that has not been looked at by regulators because of some of the hysteria I'll say it around down these meme stocks and kind of the situation it ended up in Congress, and I will charitably say there was a lot of misinformation at the hearing, and I felt kind of bad for Ken and for Vlyde and for others who were basically you know, you know they were pinionis for five and a half hours,

and I know how Washington works. It's great. I have spoken to over half a dozen Congress folks and more of their staff to try to explain, Hey, this is when you peel back the hysteria and peel back the onion and look at it. It really isn't that bad. And actually, if you're a progressive, a Democrat, whatever you want to say, you should be thrilled with this ecosystem because the three hundred five hundred dollar broker that used to rip you off by making you pay you know,

an eighth or cents spread doesn't exist anymore. So the old Wall Street way of like really taking it to the real retail investor has gone away. The retail investor is totally empowered. To use an overused word, there's been democratization now in Europe. Right, everything isn't as it's as

it's seems. Right. What the retail brokers do in Europe, which I think is actually worked worse for the investors, right, of course I'm biased, but worse with this, they just mark up the trade so you get a worse price. You get a worse price, so the bid offer that we otherwise could extract on our own right. The retail brokers effectively are charging more back to their clients, so you're getting a worse price. So which environment are you're

worse in? Would you rather pay zero commission and get the n b BO or better or I know there's a zero you know commission broker or brokers in Europe? Would you rather get that or get a price that is, instead of Joe's ten dollars for Tesla, Joe's now paying you know, ten oh one or ten oh two. I would argue, you know, you know, Joe's getting a worst deal in Europe than he is in the United States.

So you know, to me, it's just you know, regular regulators looking at this and kind of you know, in a knee jerk reaction not acting what in the best entrance of retail broke So long and short of it, I think this will get thrown back to the SEC. We have a new chairman who is a brilliant guy who I've worked with a little bit when he was at the CFTC. There's some staff folks there that have been there for a long time that know this ecosystem

exceptionally well. I think they'll look at the data, and I'm very optimistic they will conclude that this all makes sense. Wholesaling for sure makes sense. I think they will look at payment for word flow or rebates and say, maybe we need more transparency and disclosure around it, right, so clients know. But at the end of the day, if you don't want to trade with a broker that uses that does payment for water flow, then open up a new account, you know, go to Fidelity. They don't charge

payment for word flow and they have good prices. So at the end of the day, it's all about choices. I don't understand this hysteria, particularly from those that are on the left of the political spectrum, because you think it actually would fit in nicely with the whole notion of a progressive that wants to empower the little guy. The little is unbelievably empowered in this country, and yet people look at the ecosystem like somehow there's something the

fairies going on. So there's always questions of power when it comes to I mean, especially when you bring politics into it, and there's like who has the power at any given moment within existing market structure. And you mentioned that the retail brokerages that are your counterparties. They want to maintain some leverage, so they'll never give one of you guys too high market share of their flow because

they want to pit you against each other. I want to go back to something you mentioned very early in the conversation, and that is the power that the exchanges have over data and the data they sell. And I know you said you're a backer of the members exchange to one of the new like whatever eighteen stock markets there are talk to us about that power over data because I'm my understanding is that that exchange wants to sort of disrupt that a little bit. And how do

you see that, uh, that aspect of the market potentially changing. Yeah, I mean this was if go around and Google I got you know, I was pretty vocal about this. I don't know, five six years ago, I can't exactly remember, because I got annoyed that you had a duopoly effectively. You know, they had three large exchange groups and between

what is called the the SIP with a consolidated feed. Right, that's roughly five million dollars of quoting revenue that we all pay that gets disseminated to those exchanges, right, and then on top of that, the exchange is charged for what they call a private data feed, right, which we obviously have to buy because we're a low latency market making firm. And then on top of that, they charge

you for physical connectivity. So I actually went to the sec there's a article about this, when I brought like a cable that I had bought on Amazon that we paid a hundred and seventy nine dollars for, right, literally a physical Ethernet cable that connected our server to the exchange server, and NASDAC was charging us and being a little hyperbolic, but really not that much. They were charging us about a half a million dollars a year for that because there was a monthly charge for quote unquote

connect ativity. And it literally was just an Ethernet cable that you could buy. So I got Piste off and said, okay, you know, uh, physical connectivity and market data are elements of an exchange and exchange for your license from the government, right, which gets you that market data fee that I mentioned,

the SIP revenue and everything like that, and gives you immunity. Right, there's a limited liability and the securities laws, you know, you need to have the SEC approved not only just your order types, but your market data fees, your connectivities fees. It's all part of the quote unquote facilities of the exchange. You said you wanted wank, I'm giving you full on work. That's a define term in the Securities Exchange Act. The nine four used to be a partner Paul Wise. I

researched this stuff, myself, read all about it. So I went to the SEC and created a star, put in a comment letter and said, you know what, the exchanges have been getting away with this for a long time. This should be regulated, etcetera, etcetera. The politics of the moment were good because Jay Clayton and bred Redfern, who were the the chairman and the head of trading markets at the time, kind of had a similar view of the world as I did, you know, on his way

out the door, Clayton and the commissioners. You know, but I think it was a five zero vote and nothing in Washington happens unanimously anymore. Kind of agreed with the argument that I was starting to make a virtue was starting to make five years ago, that those items needed to be uh, they need to be a cost benefit analysis, right, you couldn't just every year keep charging us more and

more and more without any cost benefit. Because it was part of the quote unquote facilities of a national securities exchange that is now in litigation. Because my friends at the exchanges, who I get along great with, by the way, we're their biggest customers, they kind of have to be nice to me. They sued the sec to enjoy enforcement if you will, that regulation. So that'll be in litigation in the d C circuit probably for the next you know, five years or so, given the you know, the amount

of money here at stakes. So there's a and that that's a continuing kind of kabuki dance between the regulators SYTHEMA, which is the you know, the banks and the broke

is we're a member of SIFMA and the exchanges. This is nothing that they've been fighting over who controls that data and who can charge for it, because if you think about it, I'm creating the data, right, you know, to get back to Facebook virtue sending literally hundreds and hundreds and billions of bids and offers every day, that's

like important value of information the exchanges. I'll be a schmuck now, I'll say all they do is they take it, repackage it kind of in a crappier format, and then sell it back to us right along, let's sit it another information at a premium price. So that's what really pissed me off. That in the cable really kind of pissed me off. You're designated market maker for the bitcoin et F that exists in Canada. It just got started.

It's already from what I understand, like a huge hit in Canada in terms of like how much money it's taken in. We might get one at some point in the in the U S. What have you learned about that business? Like? How big and how interesting is that whole space? Uh? For you guys right now? Yeah. I mean, for the record, I'm not like an expert in crypto, a goodcoin or whatever it was. I'm a market maker and so my determination to get into it was okay.

When I saw that it was going to be recognized and regularized if you will buy a regulator, we think the world of right, We're a market maker up in kind of big time. And so when I Rock said that they could do this, that's the sec up there, I was like, you know, done virtues all over this because this plays right into our wheelhouse. Right, it's a in e t F with the underlying basket is a different asset class, right, That's what we're good at, and

it's and there's also a future on the CME. So there's various products we can we can move back and forth. And so I think as cryptocurrencies like bitcoined get further regularized and regulated, if you will end institutions like e t F issuers the u S securities market, future houses like the CME recognize that there's that this is a valuable asset class and include them in products right that represent the underlying coining. You're going to see an explosion

of interest because then institutions get more comfortable. Right, it's no longer the wild west of you know, a hundred venues ninety eight of which you haven't heard where you know, we trade on coin base and Gemini because we've done our diligence on them and there's no central clearing there, right,

So you're taking counterparty risk against those institutions. And so if it's you know, bitcoin venue you've never heard of, add some you know country far far away that doesn't really fit our our risk parameters, right, We're not We're

not a hedge fund, we're not day traders, right. So as it becomes more i'll say systematized, you're gonna need market making firms like Virtue to you know, provide it spread between the coin the future and the e t F. I'm hopeful that in this new administration you'll see the SEC approven in the United States as well, and we'll be a big market maker in those. A lot of people think this is going to be the year you

think it could be. I think it will be. Yeah, I think there's just too much know when you see it on TV and the price of it, there's too much mainstreaming of it, and when the institutions start buying it, and then on top of that, you know, we've got a lot of retail clients that have come to us and said, hey, we want to make this available to are a high high networks. Will you provide a two

sided price ind it. So when that happens, when names you you know of and you can read the articles, want to make it available to their high networks, then it's becoming more mainstream. And that's when obviously we need to be there as a liquidity provider. So since Joe brought up something slightly different to payment for order flow, I have one more question. Um, you mentioned the administration there, and of course one of the big proposals from the

Democrats is this idea of a financial transaction tax. How much would that affect your business? You're really trying to get me in trouble and say something really colossally stupid and offensive about the administration, aren't you. I want to hear your voice go high. I guess yeah, you want to hear my voice go high. Okay, So there's probably nothing, uh more inane than a financial transit action tax. I

have studied this backwards and forwards. I read about the Swedish transaction tax of where on Friday they closed at Reutina's market. On Monday it moved to London. Uh. What I have always said is liquidity is like water. It finds its level. So if if the folks in Washington see fit to an act of financial transaction tax, and I don't think they will because Chuck Schumer is in my view of the smartest man in the Senate, and he happens the majority leader. Smart thing. Yeah, and uh,

he happens to represent New York. He happens to understand that Wall Street and and Manhattan depend on the financial services market, and at financial transaction tax, it wouldn't just impact virtue, right, it would reduce volumes, the spreads would widen, and Mr and Mrs four oh one k would under paying the price, and the pension plans would pay the price.

So when I see, like you know, unions, public service unions advocating financial for a financial transaction tax, I say to myself, they've either been severely misled by some Washington hack that's trying to raise money, or they just don't understand how markets work, because that's just a friction in the market and what happens to the market makers and to the financial communities. We pass that cost on, right, We're not gonna go out of business and make markets,

and you're gonna still need a market maker. So we would just widen out and volumes with decline, the exchanges would be impacted, and ultimately you and I in our four oh one ks and our pension plans would pay

that price. So as a policy matter, it is a S and I. As a practical matter, it has not worked in any jurisdiction the world where it's ever been proposed and implemented, and if it ends up happy the United States, you know folks up in Canada, Bermuda, Switzerland, the UK, Singapore, they will light up alternative exchanges and all of the U S secreers will just trade on CFD over there, and the Treasury will be deeply disappointed that they won't collect bub Kiss. How's that? That's pretty good?

Your voice cone higher, But I'll I'll accept it. I can't say Bob. I can't say bubb Kiss as a soprano. It does not work. It doesn't work. That doesn't work. It doesn't work. Bubb Kiss is more of a baritone. Yes, Oh, Doug, thank you so much for coming on all thoughts. That was great. Thank you so much, guys, that was great, dog, Thank you, I appreciate it. Cheers. Nice to meet you, so, Joe.

I enjoyed that conversation. Um, it's nice to talk to Doug, and clearly he feels very passionately about a lot of these topics. One thing I was thinking is just how much different the conversation would be right now had people decided not to name dark pools dark pools or to name, you know, payment for order flow, payment for order flow, like imagine if you had a much less evocative name. Yeah, all of it very evocative, and like, you know, I think like it was you know, he talked about his

dispute with a sworking and just this whole idea. I mean, I think the dominant storyline that a lot or at least a lot of people came away with their the idea in their heads that's like payment for order flows, Like they're buying your order flow because like they want some information and so like the Facebook model is like, well, we want your information and then we're gonna sell adds

against it. Where people have this idea is like Citadel is like gonna buy your trade and then they're gonna like make their own like side beds against the trade. And I think like his description that basically it's like they make a margin on a trade and so the broker demands or could like pursue a rebate on it. It's not sexy, but I think it, Uh, it makes it makes a lot of sense as he describes it. Yeah, and also, I mean we did a whole episode on

this before. But the margin requirements for trades and the idea, the idea that if trade flow is going all in one direction, then that kind of leaves the broker at risk, and for that reason they would have to stop out the game stock trades, for instance. I thought that was a pretty clear explanation. Yeah, totally. And just beside, you know, it's like obviously on any given trade, they don't, you know,

any specific trade, they don't make much money. And so like if if trading is sort of noisy and uncorrelated and just one like random people doing whatever, then you know that's a pretty good environment. But something like Game stop. It was just I mean, that story took over the whole world for like a week, that's all anyone was talking about. And then so it's like you said this, like and that doesn't happen with a single stock trade very often, Like we're sort of used to crash a

certain use to rallies. I don't can't think of any other time we're like a single stock trade captured that much attention. But you could see then how like all of these sort of like the algorithms that they used to like put forward a price on the trade kind of got complete, would get completely busted. Yeah, and obviously that's sort of attention. It can be a good thing for businesses, you know, market making businesses, um because it

attracts additional retail trading. Or it could be a bad thing because it attracts political scrutiny and we get regulators who start to take a look at this and decide they don't like it for whatever reason. So definitely something to watch. Sounds good. I'm continuing to look forward to seeing where this guest. I got to check out the hot dogs as well. They sound good, dude, this whole to be honest, the whole time during the discussion, I've just been scrolling the hot dog all right, Um, this

has been another episode of the All Thoughts Podcast. I'm Tracy Alloway. You can follow me on Twitter at Tracy Alloway and I'm Joe Why Isn't Though. You can follow me on Twitter at the Stalwart. Follow our guest Doug Seafood on Twitter. He is at Dougie Large and really most of his tweets are about hot dogs, but maybe sometimes you'll so tweet about electronic market making. Follow our

producer Laura Carlson. She's at Laura M. Carlson. Followed the Bloomberg Head of Podcasts, Francesco Levi at Francesco Today, and check out all of our podcasts at Bloomberg under the handle at podcast Thanks for listening.