How Payment for Order Flow (PFOF) Works
What is PFOF?
PFOF is a brokerage firm's compensation for directing orders to different parties for trade execution. The brokerage firm receives fractions of a penny per share for directing the order to a market maker.
Each optionable stock could have thousands of contracts, so market makers dominate options trades. Order flow payments average less than $0.50 per option contract.
Order Flow Payments (PFOF) Explained
The proliferation of exchanges and electronic communication networks has complicated equity and options trading (ECNs) Ironically, Bernard Madoff, the Ponzi schemer, pioneered pay-for-order-flow.
In a December 2000 study on PFOF, the SEC said, "Payment for order flow is a method of transferring trading profits from market making to brokers who route customer orders to specialists for execution."
Given the complexity of trading thousands of stocks on multiple exchanges, market making has grown. Market makers are large firms that specialize in a set of stocks and options, maintaining an inventory of shares and contracts for buyers and sellers. Market makers are paid the bid-ask spread. Spreads have narrowed since 2001, when exchanges switched to decimals. A market maker's ability to play both sides of trades is key to profitability.
Benefits, requirements
A broker receives fees from a third party for order flow, sometimes without a client's knowledge. This invites conflicts of interest and criticism. Regulation NMS from 2005 requires brokers to disclose their policies and financial relationships with market makers.
Your broker must tell you if it's paid to send your orders to specific parties. This must be done at account opening and annually. The firm must disclose whether it participates in payment-for-order-flow and, upon request, every paid order. Brokerage clients can request payment data on specific transactions, but the response takes weeks.
Order flow payments save money. Smaller brokerage firms can benefit from routing orders through market makers and getting paid. This allows brokerage firms to send their orders to another firm to be executed with other orders, reducing costs. The market maker or exchange benefits from additional share volume, so it pays brokerage firms to direct traffic.
Retail investors, who lack bargaining power, may benefit from order-filling competition. Arrangements to steer the business in one direction invite wrongdoing, which can erode investor confidence in financial markets and their players.
Pay-for-order-flow criticism
It has always been controversial. Several firms offering zero-commission trades in the late 1990s routed orders to untrustworthy market makers. During the end of fractional pricing, the smallest stock spread was $0.125. Options spreads widened. Traders found that some of their "free" trades cost them a lot because they weren't getting the best price.
The SEC then studied the issue, focusing on options trades, and nearly decided to ban PFOF. The proliferation of options exchanges narrowed spreads because there was more competition for executing orders. Options market makers said their services provided liquidity. In its conclusion, the report said, "While increased multiple-listing produced immediate economic benefits to investors in the form of narrower quotes and effective spreads, these improvements have been muted with the spread of payment for order flow and internalization."
The SEC allowed payment for order flow to continue to prevent exchanges from gaining monopoly power. What would happen to trades if the practice was outlawed was also unclear. SEC requires brokers to disclose financial arrangements with market makers. Since then, the SEC has watched closely.
2020 Order Flow Payment
Rule 605 and Rule 606 show execution quality and order flow payment statistics on a broker's website. Despite being required by the SEC, these reports can be hard to find. The SEC mandated these reports in 2005, but the format and reporting requirements have changed over the years, most recently in 2018.
Brokers and market makers formed a working group with the Financial Information Forum (FIF) to standardize order execution quality reporting. Only one retail brokerage (Fidelity) and one market maker remain (Two Sigma Securities). FIF notes that the 605/606 reports "do not provide the level of information that allows a retail investor to gauge how well a broker-dealer fills a retail order compared to the NBBO (national best bid or offer’) at the time the order was received by the executing broker-dealer."
In the first quarter of 2020, Rule 606 reporting changed to require brokers to report net payments from market makers for S&P 500 and non-S&P 500 equity trades and options trades. Brokers must disclose payment rates per 100 shares by order type (market orders, marketable limit orders, non-marketable limit orders, and other orders).
Richard Repetto, Managing Director of New York-based Piper Sandler & Co., publishes a report on Rule 606 broker reports. Repetto focused on Charles Schwab, TD Ameritrade, E-TRADE, and Robinhood in Q2 2020. Repetto reported that payment for order flow was higher in the second quarter than the first due to increased trading activity, and that options paid more than equities.
Repetto says PFOF contributions rose overall. Schwab has the lowest options rates, while TD Ameritrade and Robinhood have the highest. Robinhood had the highest equity rating. Repetto assumes Robinhood's ability to charge higher PFOF reflects their order flow profitability and that they receive a fixed rate per spread (vs. a fixed rate per share by the other brokers).
Robinhood's PFOF in equities and options grew the most quarter-over-quarter of the four brokers Piper Sandler analyzed, as did their implied volumes. All four brokers saw higher PFOF rates.
TD Ameritrade took the biggest income hit when cutting trading commissions in fall 2019, and this report shows they're trying to make up the shortfall by routing orders for additional PFOF. Robinhood refuses to disclose trading statistics using the same metrics as the rest of the industry, offering only a vague explanation on their website.
Summary
Payment for order flow has become a major source of revenue as brokers offer no-commission equity (stock and ETF) orders. For retail investors, payment for order flow poses a problem because the brokerage may route orders to a market maker for its own benefit, not the investor's.
Infrequent or small-volume traders may not notice their broker's PFOF practices. Frequent traders and those who trade larger quantities should learn about their broker's order routing system to ensure they're not losing out on price improvement due to a broker prioritizing payment for order flow.
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More on Economics & Investing

Ray Dalio
3 years ago
The latest “bubble indicator” readings.
As you know, I like to turn my intuition into decision rules (principles) that can be back-tested and automated to create a portfolio of alpha bets. I use one for bubbles. Having seen many bubbles in my 50+ years of investing, I described what makes a bubble and how to identify them in markets—not just stocks.
A bubble market has a high degree of the following:
- High prices compared to traditional values (e.g., by taking the present value of their cash flows for the duration of the asset and comparing it with their interest rates).
- Conditons incompatible with long-term growth (e.g., extrapolating past revenue and earnings growth rates late in the cycle).
- Many new and inexperienced buyers were drawn in by the perceived hot market.
- Broad bullish sentiment.
- Debt financing a large portion of purchases.
- Lots of forward and speculative purchases to profit from price rises (e.g., inventories that are more than needed, contracted forward purchases, etc.).
I use these criteria to assess all markets for bubbles. I have periodically shown you these for stocks and the stock market.
What Was Shown in January Versus Now
I will first describe the picture in words, then show it in charts, and compare it to the last update in January.
As of January, the bubble indicator showed that a) the US equity market was in a moderate bubble, but not an extreme one (ie., 70 percent of way toward the highest bubble, which occurred in the late 1990s and late 1920s), and b) the emerging tech companies (ie. As well, the unprecedented flood of liquidity post-COVID financed other bubbly behavior (e.g. SPACs, IPO boom, big pickup in options activity), making things bubbly. I showed which stocks were in bubbles and created an index of those stocks, which I call “bubble stocks.”
Those bubble stocks have popped. They fell by a third last year, while the S&P 500 remained flat. In light of these and other market developments, it is not necessarily true that now is a good time to buy emerging tech stocks.
The fact that they aren't at a bubble extreme doesn't mean they are safe or that it's a good time to get long. Our metrics still show that US stocks are overvalued. Once popped, bubbles tend to overcorrect to the downside rather than settle at “normal” prices.
The following charts paint the picture. The first shows the US equity market bubble gauge/indicator going back to 1900, currently at the 40% percentile. The charts also zoom in on the gauge in recent years, as well as the late 1920s and late 1990s bubbles (during both of these cases the gauge reached 100 percent ).
The chart below depicts the average bubble gauge for the most bubbly companies in 2020. Those readings are down significantly.
The charts below compare the performance of a basket of emerging tech bubble stocks to the S&P 500. Prices have fallen noticeably, giving up most of their post-COVID gains.
The following charts show the price action of the bubble slice today and in the 1920s and 1990s. These charts show the same market dynamics and two key indicators. These are just two examples of how a lot of debt financing stock ownership coupled with a tightening typically leads to a bubble popping.
Everything driving the bubbles in this market segment is classic—the same drivers that drove the 1920s bubble and the 1990s bubble. For instance, in the last couple months, it was how tightening can act to prick the bubble. Review this case study of the 1920s stock bubble (starting on page 49) from my book Principles for Navigating Big Debt Crises to grasp these dynamics.
The following charts show the components of the US stock market bubble gauge. Since this is a proprietary indicator, I will only show you some of the sub-aggregate readings and some indicators.
Each of these six influences is measured using a number of stats. This is how I approach the stock market. These gauges are combined into aggregate indices by security and then for the market as a whole. The table below shows the current readings of these US equity market indicators. It compares current conditions for US equities to historical conditions. These readings suggest that we’re out of a bubble.
1. How High Are Prices Relatively?
This price gauge for US equities is currently around the 50th percentile.
2. Is price reduction unsustainable?
This measure calculates the earnings growth rate required to outperform bonds. This is calculated by adding up the readings of individual securities. This indicator is currently near the 60th percentile for the overall market, higher than some of our other readings. Profit growth discounted in stocks remains high.
Even more so in the US software sector. Analysts' earnings growth expectations for this sector have slowed, but remain high historically. P/Es have reversed COVID gains but remain high historical.
3. How many new buyers (i.e., non-existing buyers) entered the market?
Expansion of new entrants is often indicative of a bubble. According to historical accounts, this was true in the 1990s equity bubble and the 1929 bubble (though our data for this and other gauges doesn't go back that far). A flood of new retail investors into popular stocks, which by other measures appeared to be in a bubble, pushed this gauge above the 90% mark in 2020. The pace of retail activity in the markets has recently slowed to pre-COVID levels.
4. How Broadly Bullish Is Sentiment?
The more people who have invested, the less resources they have to keep investing, and the more likely they are to sell. Market sentiment is now significantly negative.
5. Are Purchases Being Financed by High Leverage?
Leveraged purchases weaken the buying foundation and expose it to forced selling in a downturn. The leverage gauge, which considers option positions as a form of leverage, is now around the 50% mark.
6. To What Extent Have Buyers Made Exceptionally Extended Forward Purchases?
Looking at future purchases can help assess whether expectations have become overly optimistic. This indicator is particularly useful in commodity and real estate markets, where forward purchases are most obvious. In the equity markets, I look at indicators like capital expenditure, or how much businesses (and governments) invest in infrastructure, factories, etc. It reflects whether businesses are projecting future demand growth. Like other gauges, this one is at the 40th percentile.
What one does with it is a tactical choice. While the reversal has been significant, future earnings discounting remains high historically. In either case, bubbles tend to overcorrect (sell off more than the fundamentals suggest) rather than simply deflate. But I wanted to share these updated readings with you in light of recent market activity.

Quant Galore
3 years ago
I created BAW-IV Trading because I was short on money.
More retail traders means faster, more sophisticated, and more successful methods.
Tech specifications
Only requires a laptop and an internet connection.
We'll use OpenBB's research platform for data/analysis.
Pricing and execution on Options-Quant
Background
You don't need to know the arithmetic details to use this method.
Black-Scholes is a popular option pricing model. It's best for pricing European options. European options are only exercisable at expiration, unlike American options. American options are always exercisable.
American options carry a premium to cover for the risk of early exercise. The Black-Scholes model doesn't account for this premium, hence it can't price genuine, traded American options.
Barone-Adesi-Whaley (BAW) model. BAW modifies Black-Scholes. It accounts for exercise risk premium and stock dividends. It adds the option's early exercise value to the Black-Scholes value.
The trader need not know the formulaic derivations of this model.
https://ir.nctu.edu.tw/bitstream/11536/14182/1/000264318900005.pdf
Strategy
This strategy targets implied volatility. First, we'll locate liquid options that expire within 30 days and have minimal implied volatility.
After selecting the option that meets the requirements, we price it to get the BAW implied volatility (we choose BAW because it's a more accurate Black-Scholes model). If estimated implied volatility is larger than market volatility, we'll capture the spread.
(Calculated IV — Market IV) = (Profit)
Some approaches to target implied volatility are pricey and inaccessible to individual investors. The best and most cost-effective alternative is to acquire a straddle and delta hedge. This may sound terrifying and pricey, but as shown below, it's much less so.
The Trade
First, we want to find our ideal option, so we use OpenBB terminal to screen for options that:
Have an IV at least 5% lower than the 20-day historical IV
Are no more than 5% out-of-the-money
Expire in less than 30 days
We query:
stocks/options/screen/set low_IV/scr --export Output.csv
This uses the screener function to screen for options that satisfy the above criteria, which we specify in the low IV preset (more on custom presets here). It then saves the matching results to a csv(Excel) file for viewing and analysis.
Stick to liquid names like SPY, AAPL, and QQQ since getting out of a position is just as crucial as getting in. Smaller, illiquid names have higher inefficiencies, which could restrict total profits.
We calculate IV using the BAWbisection model (the bisection is a method of calculating IV, more can be found here.) We price the IV first.
According to the BAW model, implied volatility at this level should be priced at 26.90%. When re-pricing the put, IV is 24.34%, up 3%.
Now it's evident. We must purchase the straddle (long the call and long the put) assuming the computed implied volatility is more appropriate and efficient than the market's. We just want to speculate on volatility, not price fluctuations, thus we delta hedge.
The Fun Starts
We buy both options for $7.65. (x100 multiplier). Initial delta is 2. For every dollar the stock price swings up or down, our position value moves $2.
We want delta to be 0 to avoid price vulnerability. A delta of 0 suggests our position's value won't change from underlying price changes. Being delta-hedged allows us to profit/lose from implied volatility. Shorting 2 shares makes us delta-neutral.
That's delta hedging. (Share price * shares traded) = $330.7 to become delta-neutral. You may have noted that delta is not truly 0.00. This is common since delta-hedging means getting as near to 0 as feasible, since it is rare for deltas to align at 0.00.
Now we're vulnerable to changes in Vega (and Gamma, but given we're dynamically hedging, it's not a big risk), or implied volatility. We wanted to gamble that the position's IV would climb by at least 2%, so we'll maintain it delta-hedged and watch IV.
Because the underlying moves continually, the option's delta moves continuously. A trader can short/long 5 AAPL shares at most. Paper trading lets you practice delta-hedging. Being quick-footed will help with this tactic.
Profit-Closing
As expected, implied volatility rose. By 10 minutes before market closure, the call's implied vol rose to 27% and the put's to 24%. This allowed us to sell the call for $4.95 and the put for $4.35, creating a profit of $165.
You may pull historical data to see how this trade performed. Note the implied volatility and pricing in the final options chain for August 5, 2022 (the position date).
Final Thoughts
Congratulations, that was a doozy. To reiterate, we identified tickers prone to increased implied volatility by screening OpenBB's low IV setting. We double-checked the IV by plugging the price into Options-BAW Quant's model. When volatility was off, we bought a straddle and delta-hedged it. Finally, implied volatility returned to a normal level, and we profited on the spread.
The retail trading space is very quickly catching up to that of institutions. Commissions and fees used to kill this method, but now they cost less than $5. Watching momentum, technical analysis, and now quantitative strategies evolve is intriguing.
I'm not linked with these sites and receive no financial benefit from my writing.
Tell me how your experience goes and how I helped; I love success tales.

Liam Vaughan
3 years ago
Investors can bet big on almost anything on a new prediction market.
Kalshi allows five-figure bets on the Grammys, the next Covid wave, and future SEC commissioners. Worst-case scenario
On Election Day 2020, two young entrepreneurs received a call from the CFTC chairman. Luana Lopes Lara and Tarek Mansour spent 18 months trying to start a new type of financial exchange. Instead of betting on stock prices or commodity futures, people could trade instruments tied to real-world events, such as legislation, the weather, or the Oscar winner.
Heath Tarbert, a Trump appointee, shouted "Congratulations." "You're competing with 1840s-era markets. I'm sure you'll become a powerhouse too."
Companies had tried to introduce similar event markets in the US for years, but Tarbert's agency, the CFTC, said no, arguing they were gambling and prone to cheating. Now the agency has reversed course, approving two 24-year-olds who will have first-mover advantage in what could become a huge new asset class. Kalshi Inc. raised $30 million from venture capitalists within weeks of Tarbert's call, his representative says. Mansour, 26, believes this will be bigger than crypto.
Anyone who's read The Wisdom of Crowds knows prediction markets' potential. Well-designed markets can help draw out knowledge from disparate groups, and research shows that when money is at stake, people make better predictions. Lopes Lara calls it a "bullshit tax." That's why Google, Microsoft, and even the US Department of Defense use prediction markets internally to guide decisions, and why university-linked political betting sites like PredictIt sometimes outperform polls.
Regulators feared Wall Street-scale trading would encourage investors to manipulate reality. If the stakes are high enough, traders could pressure congressional staffers to stall a bill or bet on whether Kanye West's new album will drop this week. When Lopes Lara and Mansour pitched the CFTC, senior regulators raised these issues. Politically appointed commissioners overruled their concerns, and one later joined Kalshi's board.
Will Kanye’s new album come out next week? Yes or no?
Kalshi's victory was due more to lobbying and legal wrangling than to Silicon Valley-style innovation. Lopes Lara and Mansour didn't invent anything; they changed a well-established concept's governance. The result could usher in a new era of market-based enlightenment or push Wall Street's destructive tendencies into the real world.
If Kalshi's founders lacked experience to bolster their CFTC application, they had comical youth success. Lopes Lara studied ballet at the Brazilian Bolshoi before coming to the US. Mansour won France's math Olympiad. They bonded over their work ethic in an MIT computer science class.
Lopes Lara had the idea for Kalshi while interning at a New York hedge fund. When the traders around her weren't working, she noticed they were betting on the news: Would Apple hit a trillion dollars? Kylie Jenner? "It was anything," she says.
Are mortgage rates going up? Yes or no?
Mansour saw the business potential when Lopes Lara suggested it. He interned at Goldman Sachs Group Inc., helping investors prepare for the UK leaving the EU. Goldman sold clients complex stock-and-derivative combinations. As he discussed it with Lopes Lara, they agreed that investors should hedge their risk by betting on Brexit itself rather than an imperfect proxy.
Lopes Lara and Mansour hypothesized how a marketplace might work. They settled on a "event contract," a binary-outcome instrument like "Will inflation hit 5% by the end of the month?" The contract would settle at $1 (if the event happened) or zero (if it didn't), but its price would fluctuate based on market sentiment. After a good debate, a politician's election odds may rise from 50 to 55. Kalshi would charge a commission on every trade and sell data to traders, political campaigns, businesses, and others.
In October 2018, five months after graduation, the pair flew to California to compete in a hackathon for wannabe tech founders organized by the Silicon Valley incubator Y Combinator. They built a website in a day and a night and presented it to entrepreneurs the next day. Their prototype barely worked, but they won a three-month mentorship program and $150,000. Michael Seibel, managing director of Y Combinator, said of their idea, "I had to take a chance!"
Will there be another moon landing by 2025?
Seibel's skepticism was rooted in America's historical wariness of gambling. Roulette, poker, and other online casino games are largely illegal, and sports betting was only legal in a few states until May 2018. Kalshi as a risk-hedging platform rather than a bookmaker seemed like a good idea, but convincing the CFTC wouldn't be easy. In 2012, the CFTC said trading on politics had no "economic purpose" and was "contrary to the public interest."
Lopes Lara and Mansour cold-called 60 Googled lawyers during their time at Y Combinator. Everyone advised quitting. Mansour recalls the pain. Jeff Bandman, a former CFTC official, helped them navigate the agency and its characters.
When they weren’t busy trying to recruit lawyers, Lopes Lara and Mansour were meeting early-stage investors. Alfred Lin of Sequoia Capital Operations LLC backed Airbnb, DoorDash, and Uber Technologies. Lin told the founders their idea could capitalize on retail trading and challenge how the financial world manages risk. "Come back with regulatory approval," he said.
In the US, even small bets on most events were once illegal. Under the Commodity Exchange Act, the CFTC can stop exchanges from listing contracts relating to "terrorism, assassination, war" and "gaming" if they are "contrary to the public interest," which was often the case.
Will subway ridership return to normal? Yes or no?
In 1988, as academic interest in the field grew, the agency allowed the University of Iowa to set up a prediction market for research purposes, as long as it didn't make a profit or advertise and limited bets to $500. PredictIt, the biggest and best-known political betting platform in the US, also got an exemption thanks to an association with Victoria University of Wellington in New Zealand. Today, it's a sprawling marketplace with its own subculture and lingo. PredictIt users call it "Rules Cuck Panther" when they lose on a technicality. Major news outlets cite PredictIt's odds on Discord and the Star Spangled Gamblers podcast.
CFTC limits PredictIt bets to $850. To keep traders happy, PredictIt will often run multiple variations of the same question, listing separate contracts for two dozen Democratic primary candidates, for example. A trader could have more than $10,000 riding on a single outcome. Some of the site's traders are current or former campaign staffers who can answer questions like "How many tweets will Donald Trump post from Nov. 20 to 27?" and "When will Anthony Scaramucci's role as White House communications director end?"
According to PredictIt co-founder John Phillips, politicians help explain the site's accuracy. "Prediction markets work well and are accurate because they attract people with superior information," he said in a 2016 podcast. “In the financial stock market, it’s called inside information.”
Will Build Back Better pass? Yes or no?
Trading on nonpublic information is illegal outside of academia, which presented a dilemma for Lopes Lara and Mansour. Kalshi's forecasts needed to be accurate. Kalshi must eliminate insider trading as a regulated entity. Lopes Lara and Mansour wanted to build a high-stakes PredictIt without the anarchy or blurred legal lines—a "New York Stock Exchange for Events." First, they had to convince regulators event trading was safe.
When Lopes Lara and Mansour approached the CFTC in the spring of 2019, some officials in the Division of Market Oversight were skeptical, according to interviews with people involved in the process. For all Kalshi's talk of revolutionizing finance, this was just a turbocharged version of something that had been rejected before.
The DMO couldn't see the big picture. The staff review was supposed to ensure Kalshi could complete a checklist, "23 Core Principles of a Designated Contract Market," which included keeping good records and having enough money. The five commissioners decide. With Trump as president, three of them were ideologically pro-market.
Lopes Lara, Mansour, and their lawyer Bandman, an ex-CFTC official, answered the DMO's questions while lobbying the commissioners on Zoom about the potential of event markets to mitigate risks and make better decisions. Before each meeting, they would write a script and memorize it word for word.
Will student debt be forgiven? Yes or no?
Several prediction markets that hadn't sought regulatory approval bolstered Kalshi's case. Polymarket let customers bet hundreds of thousands of dollars anonymously using cryptocurrencies, making it hard to track. Augur, which facilitates private wagers between parties using blockchain, couldn't regulate bets and hadn't stopped users from betting on assassinations. Kalshi, by comparison, argued it was doing everything right. (The CFTC fined Polymarket $1.4 million for operating an unlicensed exchange in January 2022. Polymarket says it's now compliant and excited to pioneer smart contract-based financial solutions with regulators.
Kalshi was approved unanimously despite some DMO members' concerns about event contracts' riskiness. "Once they check all the boxes, they're in," says a CFTC insider.
Three months after CFTC approval, Kalshi announced funding from Sequoia, Charles Schwab, and Henry Kravis. Sequoia's Lin, who joined the board, said Tarek, Luana, and team created a new way to invest and engage with the world.
The CFTC hadn't asked what markets the exchange planned to run since. After approval, Lopes Lara and Mansour had the momentum. Kalshi's March list of 30 proposed contracts caused chaos at the DMO. The division handles exchanges that create two or three new markets a year. Kalshi’s business model called for new ones practically every day.
Uncontroversial proposals included weather and GDP questions. Others, on the initial list and later, were concerning. DMO officials feared Covid-19 contracts amounted to gambling on human suffering, which is why war and terrorism markets are banned. (Similar logic doomed ex-admiral John Poindexter's Policy Analysis Market, a Bush-era plan to uncover intelligence by having security analysts bet on Middle East events.) Regulators didn't see how predicting the Grammy winners was different from betting on the Patriots to win the Super Bowl. Who, other than John Legend, would need to hedge the best R&B album winner?
Event contracts raised new questions for the DMO's product review team. Regulators could block gaming contracts that weren't in the public interest under the Commodity Exchange Act, but no one had defined gaming. It was unclear whether the CFTC had a right or an obligation to consider whether a contract was in the public interest. How was it to determine public interest? Another person familiar with the CFTC review says, "It was a mess." The agency didn't comment.
CFTC staff feared some event contracts could be cheated. Kalshi wanted to run a bee-endangerment market. The DMO pushed back, saying it saw two problems symptomatic of the asset class: traders could press government officials for information, and officials could delay adding the insects to the list to cash in.
The idea that traders might manipulate prediction markets wasn't paranoid. In 2013, academics David Rothschild and Rajiv Sethi found that an unidentified party lost $7 million buying Mitt Romney contracts on Intrade, a now-defunct, unlicensed Irish platform, in the runup to the 2012 election. The authors speculated that the trader, whom they dubbed the “Romney Whale,” may have been looking to boost morale and keep donations coming in.
Kalshi said manipulation and insider trading are risks for any market. It built a surveillance system and said it would hire a team to monitor it. "People trade on events all the time—they just use options and other instruments. This brings everything into the open, Mansour says. Kalshi didn't include election contracts, a red line for CFTC Democrats.
Lopes Lara and Mansour were ready to launch kalshi.com that summer, but the DMO blocked them. Product reviewers were frustrated by spending half their time on an exchange that represented a tiny portion of the derivatives market. Lopes Lara and Mansour pressed politically appointed commissioners during the impasse.
Tarbert, the chairman, had moved on, but Kalshi found a new supporter in Republican Brian Quintenz, a crypto-loving former hedge fund manager. He was unmoved by the DMO's concerns, arguing that speculation on Kalshi's proposed events was desirable and the agency had no legal standing to prevent it. He supported a failed bid to allow NFL futures earlier this year. Others on the commission were cautious but supportive. Given the law's ambiguity, they worried they'd be on shaky ground if Kalshi sued if they blocked a contract. Without a permanent chairman, the agency lacked leadership.
To block a contract, DMO staff needed a majority of commissioners' support, which they didn't have in all but a few cases. "We didn't have the votes," a reviewer says, paraphrasing Hamilton. By the second half of 2021, new contract requests were arriving almost daily at the DMO, and the demoralized and overrun division eventually accepted defeat and stopped fighting back. By the end of the year, three senior DMO officials had left the agency, making it easier for Kalshi to list its contracts unimpeded.
Today, Kalshi is growing. 32 employees work in a SoHo office with big windows and exposed brick. Quintenz, who left the CFTC 10 months after Kalshi was approved, is on its board. He joined because he was interested in the market's hedging and risk management opportunities.
Mid-May, the company's website had 75 markets, such as "Will Q4 GDP be negative?" Will NASA land on the moon by 2025? The exchange recently reached 2 million weekly contracts, a jump from where it started but still a small number compared to other futures exchanges. Early adopters are PredictIt and Polymarket fans. Bets on the site are currently capped at $25,000, but Kalshi hopes to increase that to $100,000 and beyond.
With the regulatory drawbridge down, Lopes Lara and Mansour must move quickly. Chicago's CME Group Inc. plans to offer index-linked event contracts. Kalshi will release a smartphone app to attract customers. After that, it hopes to partner with a big brokerage. Sequoia is a major investor in Robinhood Markets Inc. Robinhood users could have access to Kalshi so that after buying GameStop Corp. shares, they'd be prompted to bet on the Oscars or the next Fed commissioner.
Some, like Illinois Democrat Sean Casten, accuse Robinhood and its competitors of gamifying trading to encourage addiction, but Kalshi doesn't seem worried. Mansour says Kalshi's customers can't bet more than they've deposited, making debt difficult. Eventually, he may introduce leveraged bets.
Tension over event contracts recalls another CFTC episode. Brooksley Born proposed regulating the financial derivatives market in 1994. Alan Greenspan and others in the government opposed her, saying it would stifle innovation and push capital overseas. Unrestrained, derivatives grew into a trillion-dollar industry until 2008, when they sparked the financial crisis.
Today, with a midterm election looming, it seems reasonable to ask whether Kalshi plans to get involved. Elections have historically been the biggest draw in prediction markets, with 125 million shares traded on PredictIt for 2020. “We can’t discuss specifics,” Mansour says. “All I can say is, you know, we’re always working on expanding the universe of things that people can trade on.”
Any election contracts would need CFTC approval, which may be difficult with three Democratic commissioners. A Republican president would change the equation.
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Andy Murphy
3 years ago
Activating Your Vagus Nerve
11 science-backed ways to improve health, happiness, healing, relaxation, and mental clarity.
Vagus nerve is the main parasympathetic nervous system component.
It helps us rest and digest by slowing and stabilizing a resting heart rate, slowing and stabilizing the breath, promoting digestion, improving recovery and healing times, producing saliva, releasing endorphins and hormones like dopamine, oxytocin, and serotonin, and boosting the immune, digestive, and cardiovascular systems.
The vagus nerve sends anti-inflammatory signals to other parts of the body and is located behind the tongue, in the throat, neck, heart, lungs, abdomen, and brainstem.
Vagus means wandering in Latin. So, it's bold.
Here are 11 proven ways to boost health, happiness, and the vagus nerve.
1. Extend
“Yoga stimulates different nerves in your body, especially the vagus nerve that carries information from the brain to most of the body’s major organs, slows everything down and allows self-regulation. It’s the nerve that is associated with the parasympathetic system and emotions like love, joy, and compassion.” — Deepak Chopra
Stretching doesn't require a yoga background.
Listen to your body and ease into simple poses. This connects the mind and body.
If you're new to yoga or don't have access to an in-person class, try Yoga with Adrienne. Over 600 YouTube videos give her plenty of material.
2. Inhale
Because inhaling and exhaling activate the autonomic nervous system, we can breathe to relax.
Exhaling activates the parasympathetic nervous system (rest and digest). One inhales stress, the other exhales it.
So, faster or more intense breathing increases stress. Slower breathing relaxes us.
Breathe slowly, smoothly, and less.
Rhythmic breathing helps me relax.
What to do is as follows:
1. Take 4 smooth, forceless nose breaths.
2. Exhale smoothly and forcefully for 4 seconds
3. Don't pause at the inhale or exhale.
4. Continue for 5 minutes/40 breaths
5. Hold your breath as long as comfortable.
6. Breathe normally.
If four seconds is too long, try breathing in and out for two seconds, or in and out for three seconds, until your breath naturally relaxes. Once calmer, extend your breath.
Any consistent rhythm without force is good. Your heart will follow your lead and become coherent.
3. Chant/Hum
Singing, chanting, or humming activate the vagus nerve through the back of the throat.
Humming emits nitric oxide.
Nitric oxide improves blood circulation, blood flow, heart health, and blood pressure.
Antiviral, antibacterial, anti-inflammatory, antioxidant, and antimicrobial properties kill viruses and bacteria in the nose and throat.
Gargling water stimulates the vagus nerve.
Simple ways to heal, boost energy, and boost mood are often the healthiest. They're free and can be done anywhere.
4. Have more fun
Laughing stimulates the throat muscles, activating the vagus nerve. What's not to like? It releases dopamine.
Take time to enjoy life. Maybe it's a book, podcast, movie, socializing with friends, or laughing yoga.
Follow your bliss, as Joseph Campbell says.
Laugh at yourself
Actually. Really.
Gagging activates vagus nerve-connected muscles. Some doctors use the gag reflex to test the vagus nerve.
Grossness isn't required. While brushing, gag quickly. My girlfriend's brother always does it.
I'm done brushing when I gag, he says.
6. Take in the outdoors
Nature relaxes body and mind. Better if you can walk barefoot.
Earthing is associated with hippies dancing in daisies.
Science now supports hippies.
7. Enter some chilly water.
The diving reflex activates the vagus nerve when exposed to cold water.
The diving reflex involves holding your breath in cold water. Cold showers work best.
Within minutes of being in cold water, parasympathetic nervous system activity, which calms the body, increases.
8. Workout
Exercise increases dopamine, blood circulation, and breathing. So we feel energized, calm, and well-rested.
After resting, the parasympathetic nervous system engages.
It's worth waiting for, though.
9. Play music with brainwaves
Brainwave music harmonizes brainwave activity, boosts productivity and mental clarity, and promotes peace and relaxation by stimulating the vagus nerve.
Simply play a song.
My favorite.
10. Make gentle eyes
Eyes, like breath, often reflect inner state. Sharp, dilated, focused eyes indicate alertness.
Soft, open eyes reflect relaxation and ease. Soft eyes relax the nervous system.
This practice reduces stress, anxiety, and body tension. It's a quick and effective way to enter a calm, peaceful state.
Wild animals can be hunted one minute and graze the next.
Put it into action:
Relax while seated.
Gaze at a distant object
Use peripheral vision while looking straight ahead
Without moving your eyes, look up and down. Connect side spaces to your vision.
Focus on everything as your eyes soften.
Keep breathing
Stay as long as you like
11. Be intimate
We kiss, moan, and breathe deeper during love. We get dopamine, oxytocin, serotonin, and vagus nerve stimulation.
Why not?
To sum up
Here are 11 vagus nerve resets:
Stretch
Breathe
Hum/Chant
More humor
Amuse yourself
Spend time outdoors
Leap into chilly water
Exercise
Play music with brainwaves.
Make gentle eyes.
Be intimate
If these words have inspired you, try my favorite breathwork technique. Combining breathing, chanting, and brainwave music. Win-win-win :)

Sammy Abdullah
3 years ago
SaaS payback period data
It's ok and even desired to be unprofitable if you're gaining revenue at a reasonable cost and have 100%+ net dollar retention, meaning you never lose customers and expand them. To estimate the acceptable cost of new SaaS revenue, we compare new revenue to operating loss and payback period. If you pay back the customer acquisition cost in 1.5 years and never lose them (100%+ NDR), you're doing well.
To evaluate payback period, we compared new revenue to net operating loss for the last 73 SaaS companies to IPO since October 2017. (55 out of 73). Here's the data. 1/(new revenue/operating loss) equals payback period. New revenue/operating loss equals cost of new revenue.
Payback averages a year. 55 SaaS companies that weren't profitable at IPO got a 1-year payback. Outstanding. If you pay for a customer in a year and never lose them (100%+ NDR), you're establishing a valuable business. The average was 1.3 years, which is within the 1.5-year range.
New revenue costs $0.96 on average. These SaaS companies lost $0.96 every $1 of new revenue last year. Again, impressive. Average new revenue per operating loss was $1.59.
Loss-in-operations definition. Operating loss revenue COGS S&M R&D G&A (technical point: be sure to use the absolute value of operating loss). It's wrong to only consider S&M costs and ignore other business costs. Operating loss and new revenue are measured over one year to eliminate seasonality.
Operating losses are desirable if you never lose a customer and have a quick payback period, especially when SaaS enterprises are valued on ARR. The payback period should be under 1.5 years, the cost of new income < $1, and net dollar retention 100%.

caroline sinders
3 years ago
Holographic concerts are the AI of the Future.
A few days ago, I was discussing dall-e with two art and tech pals. One artist acquaintance said she knew a frightened illustrator. Would the ability to create anything with a click derail her career? The artist feared this. My curator friend smiled and said this has always been a dread among artists. When the camera was invented, didn't painters say this? Even in the Instagram era, painting exists.
When art and technology collide, there's room for innovation, experimentation, and fear — especially if the technology replicates or replaces art making. What is art's future with dall-e? How does technology affect music, beyond visual art? Recently, I saw "ABBA Voyage," a holographic ABBA concert in London.
"Abba voyage?" my phone asked in early March. A Gen X friend I met through a fashion blogging ring texted me.
"What's abba Voyage?" I asked while opening my front door with keys and coffee.
We're going! Marti, visiting London, took me to a show.
"Absolutely no ABBA songs here." I responded.
My parents didn't play ABBA much, so I don't know much about them. Dad liked Jimi Hendrix, Cream, Deep Purple, and New Orleans jazz. Marti told me ABBA Voyage was a holographic ABBA show with a live band.
The show was fun, extraordinary fun. Nearly everyone on the dance floor wore wigs, ankle-breaking platforms, sequins, and bellbottoms. I saw some millennials and Zoomers among the boomers.
I was intoxicated by the experience.
Automatons date back to the 18th-century mechanical turk. The mechanical turk was a chess automaton operated by a person. The mechanical turk seemed to perform like a human without human intervention, but it required a human in the loop to work properly.
Humans have used non-humans in entertainment for centuries, such as puppets, shadow play, and smoke and mirrors. A show can have animatronic, technological, and non-technological elements, and a live show can blur real and illusion. From medieval puppet shows to mechanical turks to AI filters, bots, and holograms, entertainment has evolved over time.
I'm not a hologram skeptic, but I'm skeptical of technology, especially since I work with it. I love live performances, I love hearing singers breathe, forget lines, and make jokes. Live shows are my favorite because I love watching performers make mistakes or interact with the audience. ABBA Voyage was different.
Marti and I traveled to Manchester after ABBA Voyage to see Liam Gallagher. Similar but different vibe. Similar in that thousands dressed up for the show. ABBA's energy was dizzying. 90s chic replaced sequins in the crowd. Doc Martens, nylon jackets, bucket hats, shaggy hair. The Charlatans and Liam Gallagher opened and closed, respectively. Fireworks. Incredible. People went crazy. Yelling exhausted my voice.
This week in music featured AI-enabled holograms and a decades-old rocker. Both are warm and gooey in our memories.
After seeing both, I'm wondering if we need AI hologram shows. Why? Is it good?
Like everything tech-related, my answer is "maybe." Because context and performance matter. Liam Gallagher and ABBA both had great, different shows.
For a hologram to work, it must be impossible and big. It must be big, showy, and improbable to justify a hologram. It must feel...expensive, like a stadium pop show. According to a quick search, ABBA broke up on bad terms. Reuniting is unlikely. This is also why Prince or Tupac hologram shows work. We can only engage with their legacy through covers or...holograms.
I drove around listening to the radio a few weeks ago. "Dreaming of You" by Selena played. Selena's music defined my childhood. I sang along and turned up the volume (or as loud as my husband would allow me while driving on the highway).
I discovered Selena's music six months after her death, so I never saw her perform live. My babysitter Melissa played me her album after I moved to Houston. Melissa took me to see the Selena movie five times when it came out. I quickly wore out my VHS copy. I constantly sang "Bibi Bibi Bom Bom" and "Como la Flor." I love Selena. A Selena hologram? Yes, probably.
Instagram advertised a cellist's Arthur Russell tribute show. Russell is another deceased artist I love. I almost walked down the aisle to "This is How We Walk on the Moon," but our cellist couldn't find it. Instead, I walked to Magnetic Fields' "The Book of Love." I "discovered" Russell after a friend introduced me to his music a few years ago.
I use these as analogies for the Liam Gallagher and ABBA concerts.
You have no idea how much I'd pay to see a hologram of Selena's 1995 Houston Livestock Show and Rodeo concert. Arthur Russell's hologram is unnecessary. Russell's work was intimate and performance-based. We can't separate his life from his legacy; popular audiences overlooked his genius. He died of AIDS broke. Like Selena, he died prematurely. Given his music and history, another performer would be a better choice than a hologram. He's no Selena. Selena could have rivaled Beyonce.
Pop shows' size works for holograms. Along with ABBA holograms, there was an anime movie and a light show that would put Tron to shame. ABBA created a tourable stadium show. The event was lavish, expensive, and well-planned. Pop, unlike rock, isn't gritty. Liam Gallagher hologram? No longer impossible, it wouldn't work. He's touring. I'm not sure if a rockstar alone should be rendered as a hologram; it was the show that made ABBA a hologram.
Holograms, like AI, are part of the future of entertainment, but not all of it. Because only modern interpretations of Arthur Russell's work reveal his legacy. That's his legacy.
Large-scale arena performers may use holograms in the future, but the experience must be impossible. A teacher once said that the only way to convey emotion in opera is through song, and I feel the same way about holograms, AR, VR, and mixed reality. A story's impossibility must make sense, like in opera. Impossibility and bombastic performance must be present for an immersive element to "work." ABBA was an impossible and improbable experience, which made it magical. It helped the holographic show work.
Marti told me about ABBA Voyage. She said it was a great concert. Marti has worked in music since the 1990s. She's a music expert; she's seen many shows.
Ai isn't a god or sentient, and the ABBA holograms aren't real. The renderings were glassy-eyed, flat, and robotic, like the Polar Express or the Jaws shark. Even today, the uncanny valley is insurmountable. We know it's not real because it's not about reality. It was about a suspended moment and performance feelings.
I knew this was impossible, an 'unreal' experience, but the emotions I felt were real, like watching a movie or tv show. Perhaps this is one of the better uses of AI, like CGI and special effects, like the beauty of entertainment- we were enraptured and entertained for hours. I've been playing ABBA since then.
