Odd Lots

Securities Information Processor (“SIP”) Operating Committees are considering a proposal for the SIPs to disseminate certain consolidated odd lot quotation data as ancillary information on the SIP data feeds. They are seeking feedback on the below draft proposal.


The Participants of the Nasdaq Unlisted Trading Privileges (UTP) Plan and the Consolidated Quotation (CQ) Plan operate the SIPs that are responsible for disseminating the national best bid and national best offer (NBBO) for quotations in NMS stocks. Pursuant to Regulation NMS, the NBBO as disseminated by the SIPs is calculated using bids and offers to buy or sell one or more round lots of an NMS stock1. Round lots are defined by the exchanges and generally refer to quotes to buy or sell 100 shares of a given security or a larger number of shares divisible by 100. Odd lots, or orders for fewer than 100 shares, are not included in the NBBO and are not currently distributed by the SIPs.

Over the past several years, the U.S. equity markets have transformed in a number of ways. One important development has been the significant increase in odd lot activity, which has come to account for an increasing portion of U.S. equity trading volume, particularly for high-priced securities2. Given the higher levels of odd lot activity, the Participants are considering ways to enhance the transparency of odd lot data. As an initial first step, the Participants are considering a proposal for the SIPs to disseminate certain consolidated odd lot quotation data as ancillary information on the SIP data feeds. The Participants believe that this new published data may provide market participants with important additional information about the price and liquidity of NMS stocks, and may be valuable for retail investors that trade in smaller share amounts, particularly in higher-priced securities.

Details on the Participants’ proposal are contained in the document below.

Odd Lot Proposal

1. The NBBO is defined under Rule 600(b)(43) of Regulation NMS to mean, “with respect to quotations for an NMS security, the best bid and best offer for such security that are calculated and disseminated” by the SIP Plans. “Bid” and “offer” are in turn defined under Rule 600(b)(9) to mean the bid price or offer price at which an exchange or FINRA member is “willing to buy or sell one or more round lots of an NMS security.”

2. For example, a recent market structure analysis, using data from the SEC’s Market Information Data Analytics System (MIDAS), found that odd lot trading in U.S. stocks increased from 5.7% of volume and 21% of trades in 2013 to almost 11% of volume and 38% of trades in 2018. See Deutsche Bank, There’s More to Odd Lots than High-Priced Stocks… (June 25, 2019).


The Participants are making this draft proposal public in the hopes that industry members and individuals will read it and submit comments on the proposal.

The official Comment Period lasts 45 days, from October 2, 2019 to November 15, 2019. Comments submitted after the deadline will continue to be accepted, but run the risk of being too late to be considered.

Please read the instructions below before emailing your comment.

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Submit Comment or send an email to [email protected]

Comments submitted to the SIP Operating Committees will be reviewed and then posted on this site, usually within 2 to 3 business days. The Operating Committees plan to publish all comments submitted, but reserve the right to discard comments that include foul or inappropriate language or are not on the topic of Odd Lots.

For any questions about Submissions, please contact Forefront Communications at [email protected]


Alex Sadowski, IntelligentCross, comments12/9/2019
Hubert De Jesus and Joanne Medero, BlackRock, comments12/3/2019
T.R. Lazo, SIFMA, comments11/26/2019
Benjamin Connault/Lucy Malcolm, IEX, comments11/18/2019
Joseph Kinahan, TD Ameritrade, comments11/15/2019
Tim Lang, ACS Execution Services, comments11/15/2019
Kelvin To, Data Boiler Technologies, comments11/15/2019
Jeffrey Kimsey, Nasdaq, comments11/15/2019
Ray Ross, Clearpool, comments11/15/2019
Stephen John Berger, Citadel, comments11/15/2019
Jeff Starr, Charles Schwab, comments11/14/2019
Anonymous, comments11/14/2019
Anonymous, comments11/08/2019
Anonymous, comments11/08/2019
Tyler Gellasch, Healthy Markets, comments10/30/2019