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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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.

Sylvain Saurel
3 years ago
A student trader from the United States made $110 million in one month and rose to prominence on Wall Street.
Genius or lucky?
From the title, you might think I'm selling advertising for a financial influencer, a dubious trading site, or a training organization to attract clients. I'm suspicious. Better safe than sorry.
But not here.
Jake Freeman, 20, made $110 million in a month, according to the Financial Times. At 18, he ran for president. He made his name in markets, not politics. Two years later, he's Wall Street's prince. Interview requests flood the prodigy.
Jake Freeman bought 5 million Bed Bath & Beyond Group shares for $5.5 in July 2022 and sold them for $27 a month later. He thought the stock might double. Since speculation died down, he sold well. The stock fell 40.5% to 11 dollars on Friday, 19 August 2022. On August 22, 2022, it fell 16% to $9.
Smallholders have been buying the stock for weeks and will lose heavily if it falls further. Bed Bath & Beyond is the second most popular stock after Foot Locker, ahead of GameStop and Apple.
Jake Freeman earned $110 million thanks to a significant stock market flurry.
Online broker customers aren't the only ones with jitters. By June 2022, Ken Griffin's Citadel and Stephen Mandel's Lone Pine Capital held nearly a third of the company's capital. Did big managers sell before the stock plummeted?
Recent stock movements (derivatives) and rumors could prompt a SEC investigation.
Jake Freeman wrote to the board of directors after his investment to call for a turnaround, given the company's persistent problems and short sellers. The bathroom and kitchen products distribution group's stock soared in July 2022 due to renewed buying by private speculators, who made it one of their meme stocks with AMC and GameStop.
Second-quarter 2022 results and financial health worsened. He didn't celebrate his miraculous operation in a nightclub. He told a British newspaper, "I'm shocked." His parents dined in New York. He returned to Los Angeles to study math and economics.
Jake Freeman founded Freeman Capital Management with his savings and $25 million from family, friends, and acquaintances. They are the ones who are entitled to the $110 million he raised in one month. Will his investors pocket and withdraw all or part of their profits or will they trust the young prodigy for new stunts on Wall Street?
His operation should attract new clients. Well-known hedge funds may hire him.
Jake Freeman didn't listen to gurus or former traders. At 17, he interned at a quantitative finance and derivatives hedge fund, Volaris. At 13, he began investing with his pharmaceutical executive uncle. All countries have increased their Google searches for the young trader in the last week.
Naturally, his success has inspired resentment.
His success stirs jealousy, and he's attacked on social media. On Reddit, people who lost money on Bed Bath & Beyond, Jake Freeman's fortune, are mourning.
Several conspiracy theories circulate about him, including that he doesn't exist or is working for a Taiwanese amusement park.
If all 20 million American students had the same trading skills, they would have generated $1.46 trillion. Jake Freeman is unique. Apprentice traders' careers are often short, disillusioning, and tragic.
Two years ago, 20-year-old Robinhood client Alexander Kearns committed suicide after losing $750,000 trading options. Great traders start young. Michael Platt of BlueCrest invested in British stocks at age 12 under his grandmother's supervision and made a £30,000 fortune. Paul Tudor Jones started trading before he turned 18 with his uncle. Warren Buffett, at age 10, was discussing investments with Goldman Sachs' head. Oracle of Omaha tells all.

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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Aldric Chen
3 years ago
Jack Dorsey's Meeting Best Practice was something I tried. It Performs Exceptionally Well in Consulting Engagements.
Yes, client meetings are difficult. Especially when I'm alone.
Clients must tell us their problems so we can help.
In-meeting challenges contribute nothing to our work. Consider this:
Clients are unprepared.
Clients are distracted.
Clients are confused.
Introducing Jack Dorsey's Google Doc approach
I endorse his approach to meetings.
Not Google Doc-related. Jack uses it for meetings.
This is what his meetings look like.
Prior to the meeting, the Chair creates the agenda, structure, and information using Google Doc.
Participants in the meeting would have 5-10 minutes to read the Google Doc.
They have 5-10 minutes to type their comments on the document.
In-depth discussion begins
There is elegance in simplicity. Here's how Jack's approach is fantastic.
Unprepared clients are given time to read.
During the meeting, they think and work on it.
They can see real-time remarks from others.
Discussion ensues.
Three months ago, I fell for this strategy. After trying it with a client, I got good results.
I conducted social control experiments in a few client workshops.
Context matters.
I am sure Jack Dorsey’s method works well in meetings. What about client workshops?
So, I tested Enterprise of the Future with a consulting client.
I sent multiple emails to client stakeholders describing the new approach.
No PowerPoints that day. I spent the night setting up the Google Doc with conversation topics, critical thinking questions, and a Before and After section.
The client was shocked. First, a Google Doc was projected. Second surprise was a verbal feedback.
“No pre-meeting materials?”
“Don’t worry. I know you are not reading it before our meeting, anyway.”
We laughed. The experiment started.
Observations throughout a 90-minute engagement workshop from beginning to end
For 10 minutes, the workshop was silent.
People read the Google Doc. For some, the silence was unnerving.
“Are you not going to present anything to us?”
I said everything's in Google Doc. I asked them to read, remark, and add relevant paragraphs.
As they unlocked their laptops, they were annoyed.
Ten client stakeholders are typing on the Google Doc. My laptop displays comment bubbles, red lines, new paragraphs, and strikethroughs.
The first 10 minutes were productive. Everyone has seen and contributed to the document.
I was silent.
The move to a classical workshop was smooth. I didn't stimulate dialogue. They did.
Stephanie asked Joe why a blended workforce hinders company productivity. She questioned his comments and additional paragraphs.
That is when a light bulb hit my head. Yes, you want to speak to the right person to resolve issues!
Not only that was discussed. Others discussed their remark bubbles with neighbors. Debate circles sprung up one after the other.
The best part? I asked everyone to add their post-discussion thoughts on a Google Doc.
After the workshop, I have:
An agreement-based working document
A post-discussion minutes that are prepared for publication
A record of the discussion points that were brought up, argued, and evaluated critically
It showed me how stakeholders viewed their Enterprise of the Future. It allowed me to align with them.
Finale Keynotes
Client meetings are a hit-or-miss. I know that.
Jack Dorsey's meeting strategy works for consulting. It promotes session alignment.
It relieves clients of preparation.
I get the necessary information to advance this consulting engagement.
It is brilliant.
INTΞGRITY team
3 years ago
Privacy Policy
Effective date: August 31, 2022
This Privacy Statement describes how INTΞGRITY ("we," or "us") collects, uses, and discloses your personal information. This Privacy Statement applies when you use our websites, mobile applications, and other online products and services that link to this Privacy Statement (collectively, our "Services"), communicate with our customer care team, interact with us on social media, or otherwise interact with us.
This Privacy Policy may be modified from time to time. If we make modifications, we will update the date at the top of this policy and, in certain instances, we may give you extra notice (such as adding a statement to our website or providing you with a notification). We encourage you to routinely review this Privacy Statement to remain informed about our information practices and available options.
INFORMATION COLLECTION
The Data You Provide to Us
We collect information that you directly supply to us. When you register an account, fill out a form, submit or post material through our Services, contact us via third-party platforms, request customer assistance, or otherwise communicate with us, you provide us with information directly. We may collect your name, display name, username, bio, email address, company information, your published content, including your avatar image, photos, posts, responses, and any other information you voluntarily give.
In certain instances, we may collect the information you submit about third parties. We will use your information to fulfill your request and will not send emails to your contacts unrelated to your request unless they separately opt to receive such communications or connect with us in some other way.
We do not collect payment details via the Services.
Automatically Collected Information When You Communicate with Us
In certain cases, we automatically collect the following information:
We gather data regarding your behavior on our Services, such as your reading history and when you share links, follow users, highlight posts, and like posts.
Device and Usage Information: We gather information about the device and network you use to access our Services, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information regarding your activities on our Services, including access times, pages viewed, links clicked, and the page you visited immediately prior to accessing our Services.
Information Obtained Through Cookies and Comparable Tracking Technologies: We collect information about you through tracking technologies including cookies and web beacons. Cookies are little data files kept on your computer's hard disk or device's memory that assist us in enhancing our Services and your experience, determining which areas and features of our Services are the most popular, and tracking the number of visitors. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic pictures that we employ on our Services and in our communications to assist with cookie delivery, session tracking, and usage analysis. We also partner with third-party analytics providers who use cookies, web beacons, device identifiers, and other technologies to collect information regarding your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, and links clicked. INTΞGRITY and others may use your information to, among other things, analyze and track data, evaluate the popularity of certain content, present content tailored to your interests on our Services, and better comprehend your online activities. See Your Options for additional information on cookies and how to disable them.
Information Obtained from Outside Sources
We acquire information from external sources. We may collect information about you, for instance, through social networks, accounting service providers, and data analytics service providers. In addition, if you create or log into your INTΞGRITY account via a third-party platform (such as Apple, Facebook, Google, or Twitter), we will have access to certain information from that platform, including your name, lists of friends or followers, birthday, and profile picture, in accordance with the authorization procedures determined by that platform.
We may derive information about you or make assumptions based on the data we gather. We may deduce your location based on your IP address or your reading interests based on your reading history, for instance.
USAGE OF INFORMATION
We use the information we collect to deliver, maintain, and enhance our Services, including publishing and distributing user-generated content, and customizing the posts you see. Additionally, we utilize collected information to: create and administer your INTΞGRITY account;
Send transaction-related information, including confirmations, receipts, and user satisfaction surveys;
Send you technical notices, security alerts, and administrative and support messages;
Respond to your comments and queries and offer support;
Communicate with you about new INTΞGRITY content, goods, services, and features, as well as other news and information that we believe may be of interest to you (see Your Choices for details on how to opt out of these communications at any time);
Monitor and evaluate usage, trends, and activities associated with our Services;
Detect, investigate, and prevent security incidents and other harmful, misleading, fraudulent, or illegal conduct, and safeguard INTΞGRITY’s and others' rights and property;
Comply with our legal and financial requirements; and Carry out any other purpose specified to you at the time the information was obtained.
SHARING OF INFORMATION
We share personal information where required by law or as otherwise specified in this policy:
Personal information is shared with other Service users. If you use our Services to publish content, make comments, or send private messages, for instance, certain information about you, such as your name, photo, bio, and other account information you may supply, as well as information about your activity on our Services, will be available to others (e.g., your followers and who you follow, recent posts, likes, highlights, and responses).
We share personal information with vendors, service providers, and consultants who require access to such information to perform services on our behalf, such as companies that assist us with web hosting, storage, and other infrastructure, analytics, fraud prevention, and security, customer service, communications, and marketing.
We may release personally identifiable information if we think that doing so is in line with or required by any relevant law or legal process, including authorized demands from public authorities to meet national security or law enforcement obligations. If we intend to disclose your personal information in response to a court order, we will provide you with prior notice so that you may contest the disclosure (for example, by seeking court intervention), unless we are prohibited by law or believe that doing so could endanger others or lead to illegal conduct. We shall object to inappropriate legal requests for information regarding users of our Services.
If we believe your actions are inconsistent with our user agreements or policies, if we suspect you have violated the law, or if we believe it is necessary to defend the rights, property, and safety of INTΞGRITY, our users, the public, or others, we may disclose your personal information.
We share personal information with our attorneys and other professional advisers when necessary for obtaining counsel or otherwise protecting and managing our business interests.
We may disclose personal information in conjunction with or during talks for any merger, sale of corporate assets, financing, or purchase of all or part of our business by another firm.
Personal information is transferred between and among INTΞGRITY, its current and future parents, affiliates, subsidiaries, and other companies under common ownership and management.
We will only share your personal information with your permission or at your instruction.
We also disclose aggregated or anonymized data that cannot be used to identify you.
IMPLEMENTATIONS FROM THIRD PARTIES
Some of the content shown on our Services is not hosted by INTΞGRITY. Users are able to publish content hosted by a third party but embedded in our pages ("Embed"). When you interact with an Embed, it can send information to the hosting third party just as if you had visited the hosting third party's website directly. When you load an INTΞGRITY post page with a YouTube video Embed and view the video, for instance, YouTube collects information about your behavior, such as your IP address and how much of the video you watch. INTΞGRITY has no control over the information that third parties acquire via Embeds or what they do with it. This Privacy Statement does not apply to data gathered via Embeds. Before interacting with the Embed, it is recommended that you review the privacy policy of the third party hosting the Embed, which governs any information the Embed gathers.
INFORMATION TRANSFER TO THE UNITED STATES AND OTHER NATIONS
INTΞGRITY’s headquarters are located in the United States, and we have operations and service suppliers in other nations. Therefore, we and our service providers may transmit, store, or access your personal information in jurisdictions that may not provide a similar degree of data protection to your home jurisdiction. For instance, we transfer personal data to Amazon Web Services, one of our service providers that processes personal information on our behalf in numerous data centers throughout the world, including those indicated above. We shall take measures to guarantee that your personal information is adequately protected in the jurisdictions where it is processed.
YOUR SETTINGS
Account Specifics
You can access, modify, delete, and export your account information at any time by login into the Services and visiting the Settings page. Please be aware that if you delete your account, we may preserve certain information on you as needed by law or for our legitimate business purposes.
Cookies
The majority of web browsers accept cookies by default. You can often configure your browser to delete or refuse cookies if you wish. Please be aware that removing or rejecting cookies may impact the accessibility and performance of our services.
Communications
You may opt out of getting certain messages from us, such as digests, newsletters, and activity notifications, by following the instructions contained within those communications or by visiting the Settings page of your account. Even if you opt out, we may still send you emails regarding your account or our ongoing business relationships.
Mobile Push Notifications
We may send push notifications to your mobile device with your permission. You can cancel these messages at any time by modifying your mobile device's notification settings.
YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act, or "CCPA" (Cal. Civ. Code 1798.100 et seq. ), grants California residents some rights regarding their personal data. If you are a California resident, you are subject to this clause.
We have collected the following categories of personal information over the past year: identifiers, commercial information, internet or other electronic network activity information, and conclusions. Please refer to the section titled "Collection of Information" for specifics regarding the data points we gather and the sorts of sources from which we acquire them. We collect personal information for the business and marketing purposes outlined in the section on Use of Information. In the past 12 months, we have shared the following types of personal information to the following groups of recipients for business purposes:
Category of Personal Information: Identifiers
Categories of Recipients: Analytics Providers, Communication Providers, Custom Service Providers, Fraud Prevention and Security Providers, Infrastructure Providers, Marketing Providers, Payment Processors
Category of Personal Information: Commercial Information
Categories of Recipients: Analytics Providers, Infrastructure Providers, Payment Processors
Category of Personal Information: Internet or Other Electronic Network Activity Information
Categories of Recipients: Analytics Providers, Infrastructure Providers
Category of Personal Information: Inferences
Categories of Recipients: Analytics Providers, Infrastructure Providers
INTΞGRITY does not sell personally identifiable information.
You have the right, subject to certain limitations: (1) to request more information about the categories and specific pieces of personal information we collect, use, and disclose about you; (2) to request the deletion of your personal information; (3) to opt out of any future sales of your personal information; and (4) to not be discriminated against for exercising these rights. You may submit these requests by email to hello@int3grity.com. We shall not treat you differently if you exercise your rights under the CCPA.
If we receive your request from an authorized agent, we may request proof that you have granted the agent a valid power of attorney or that the agent otherwise possesses valid written authorization to submit requests on your behalf. This may involve requiring identity verification. Please contact us if you are an authorized agent wishing to make a request.
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
This section applies to you if you are based in the European Economic Area ("EEA"), the United Kingdom, or Switzerland and have specific rights and safeguards regarding the processing of your personal data under relevant law.
Legal Justification for Processing
We will process your personal information based on the following legal grounds:
To fulfill our obligations under our agreement with you (e.g., providing the products and services you requested).
When we have a legitimate interest in processing your personal information to operate our business or to safeguard our legitimate interests, we will do so (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
To meet our legal responsibilities (e.g., to maintain a record of your consents and track those who have opted out of non-administrative communications).
If we have your permission to do so (e.g., when you opt in to receive non-administrative communications from us). When consent is the legal basis for our processing of your personal information, you may at any time withdraw your consent.
Data Retention
We retain the personal information associated with your account so long as your account is active. If you close your account, your account information will be deleted within 14 days. We retain other personal data for as long as is required to fulfill the objectives for which it was obtained and for other legitimate business purposes, such as to meet our legal, regulatory, or other compliance responsibilities.
Data Access Requests
You have the right to request access to the personal data we hold on you and to get your data in a portable format, to request that your personal data be rectified or erased, and to object to or request that we restrict particular processing, subject to certain limitations. To assert your legal rights:
If you sign up for an INTΞGRITY account, you can request an export of your personal information at any time via the Settings website, or by visiting Settings and selecting Account from inside our app.
You can edit the information linked with your account on the Settings website, or by navigating to Settings and then Account in our app, and the Customize Your Interests page.
You may withdraw consent at any time by deleting your account via the Settings page, or by visiting Settings and then selecting Account within our app (except to the extent INTΞGRITY is prevented by law from deleting your information).
You may object to the use of your personal information at any time by contacting hello@int3grity.com.
Questions or Complaints
If we are unable to settle your concern over our processing of personal data, you have the right to file a complaint with the Data Protection Authority in your country. The links below provide access to the contact information for your Data Protection Authority.
For people in the EEA, please visit https://edpb.europa.eu/about-edpb/board/members en.
For persons in the United Kingdom, please visit https://ico.org.uk/global/contact-us.
For people in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
CONTACT US
Please contact us at hello@int3grity.com if you have any queries regarding this Privacy Statement.

William Anderson
3 years ago
When My Remote Leadership Skills Took Off
4 Ways To Manage Remote Teams & Employees
The wheels hit the ground as I landed in Rochester.
Our six-person satellite office was now part of my team.
Their manager only reported to me the day before, but I had my ticket booked ahead of time.
I had managed remote employees before but this was different. Engineers dialed into headquarters for every meeting.
So when I learned about the org chart change, I knew a strong first impression would set the tone for everything else.
I was either their boss, or their boss's boss, and I needed them to know I was committed.
Managing a fleet of satellite freelancers or multiple offices requires treating others as more than just a face behind a screen.
You must comprehend each remote team member's perspective and daily interactions.
The good news is that you can start using these techniques right now to better understand and elevate virtual team members.
1. Make Visits To Other Offices
If budgeted, visit and work from offices where teams and employees report to you. Only by living alongside them can one truly comprehend their problems with communication and other aspects of modern life.
2. Have Others Come to You
• Having remote, distributed, or satellite employees and teams visit headquarters every quarter or semi-quarterly allows the main office culture to rub off on them.
When remote team members visit, more people get to meet them, which builds empathy.
If you can't afford to fly everyone, at least bring remote managers or leaders. Hopefully they can resurrect some culture.
3. Weekly Work From Home
No home office policy?
Make one.
WFH is a team-building, problem-solving, and office-viewing opportunity.
For dial-in meetings, I started working from home on occasion.
It also taught me which teams “forget” or “skip” calls.
As a remote team member, you experience all the issues first hand.
This isn't as accurate for understanding teams in other offices, but it can be done at any time.
4. Increase Contact Even If It’s Just To Chat
Don't underestimate office banter.
Sometimes it's about bonding and trust, other times it's about business.
If you get all this information in real-time, please forward it.
Even if nothing critical is happening, call remote team members to check in and chat.
I guarantee that building relationships and rapport will increase both their job satisfaction and yours.
