Why Robinhood’s Payment for Order Flow System Is an Issue for Users

Scott Galloway is a bestselling creator and professor of selling at NYU Stern.
The following is a latest weblog publish, republished with permission, that initially ran on his weblog, “No Mercy / No Malice.”
In it, Galloway calls the fee for order circulate (PFOF) system that Robinhood makes use of “internet online affiliate marketing” for funds.

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Robinhood went public on Thursday, the old school means — by way of an IPO with underwriters after a roadshow. The IPO priced at $38 per share, yielding a valuation of $32 billion, and closed its first day of buying and selling down 8.4%. The buying and selling firm’s debut is the worst on document among the many 51 US companies which have raised as a lot money as Robinhood. (Disclosure: I’m an investor in Public.com.)So what’s going to $30 billion purchase? At first look, Robinhood is a roaring success. In 2020 it registered income of $959 million, a 245% enhance from 2019. RH boasted 18 million month-to-month energetic customers in March 2021, up from 7 million a 12 months prior. And in step with the corporate’s thesis, “to democratize finance for all,” feminine customers tripled over the previous 12 months and greater than 25% of customers are actually folks of coloration, considerably greater than on the incumbent brokerage homes.However … I’ve written earlier than concerning the problematic features of Robinhood’s gamification of investing. The firm preys on human weak point, particularly younger males’s susceptibility to playing dependancy. That’s nonetheless true, and RH’s IPO warrants a deeper dive into the agency’s enterprise mannequin.What is Robinhood?The firm operates a cellular app that permits shoppers to commerce shares, choices, and crypto. These orders are the corporate’s stock, which it sells to “market makers” — giant monetary establishments that pare (execute) the trades available in the market. As with Google or Facebook, Robinhood’s customers will not be its prospects, however its provide.

Scott Galloway

This means Robinhood is incentivized to maintain its customers buying and selling … rather a lot. The purpose: make inventory buying and selling as addictive as social media scrolling. RH has loved success right here. The proportion of customers who verify it day by day rivals these of Twitter, Snapchat, and Facebook.Various monetary merchandise drive the corporate’s income, however one is particularly profitable: choices. RH makes at the least twice as a lot per choices commerce than it does on a inventory commerce. Why? Because market makers pay extra for choices than shares. Options buying and selling is much less liquid than inventory buying and selling, which interprets to higher bid/ask spreads for the market makers. RH depends on market makers, and market makers love choices. The transitive property tells us the corporate depends on choices, as evidenced by its income combine. Despite making up solely 3% of RH’s property below custody, choices drive 46% of complete income.

Scott Galloway

FYI: Options do not present any precise fairness in an organization. They solely allow you to purchase or promote a inventory at a given value inside a finite interval. Put one other means, they’re 1) extremely speculative and a pair of) dangerous. RH is extra gaming app than funding app. Keep in thoughts, 43% of its customers have FICO scores beneath 650.Payment for order circulate (PFOF)Robinhood’s incentive to drive traders towards day buying and selling choices isn’t the one fissure between customers’ pursuits and its personal.

The transaction on the coronary heart of the corporate’s mannequin is “Payment for Order Flow” or PFOF. Because RH generates its income by promoting orders to market makers, it would not cost commissions to its client customers. But this additionally creates a battle of curiosity for the corporate, which is motivated to promote orders to the market maker that provides the best fee for the commerce slightly than the perfect value. It’s like internet online affiliate marketing, however for your monetary future.PFOF goes again to the Nineteen Eighties, when it was pioneered by, wait for it … Bernie Madoff. Madoff relied on the apply to make his agency one of many main market makers of its day, and when regulators raised questions on whether or not it offered a battle of curiosity, he used his place because the chairperson of Nasdaq to forestall restrictions. (PFOF is unlawful within the UK) There was no battle of curiosity, Madoff assured his colleagues, as a result of “there are very strict guidelines that I might assume most companies adjust to.”Regulatory overrunRobinhood is the newest instance of an rising development: tech corporations for whom illegality is a characteristic, not a bug. Uber is an $86 billion gypsy cab firm. Facebook and Google have acquired so many fines, it is probably the businesses internally classify them as a value of doing enterprise. This is tantamount to changing civics programs with jail coaching, as a result of … effectively … that is how we roll.For its half, RH has racked up: a $70 million settlement with FINRA, a $65 million SEC advantageous (for failing to correctly disclose PFOF), and a separate $1.25 million FINRA advantageous. And on Wednesday, on the eve of pricing its IPO, the corporate disclosed that its senior executives are below investigation by FINRA for failing to amass broker-dealer licenses. In addition, one other inquiry is below means into the likelihood that RH workers made unlawful insider trades in the course of the GameStop frenzy early this 12 months.

Once, that sort of disclosure would have dismembered an IPO. Instead, 48 hours after it made the disclosure, Robinhood was publicly buying and selling at $32 billion. Telling level: The firm paid its chief authorized officer, Daniel Gallagher, greater than $30 million in 2020, though it employed him midway by means of the 12 months. From 2011 to 2015, Gallagher was an SEC Commissioner. Our enterprise setting has morphed from capitalism, which is determined by the principles of honest play, into cronyism.

Scott Galloway

Flouting the legislation is now a sign to traders {that a} agency is “disruptive.” Established corporations, which imagine they’ve an excessive amount of to lose, have spent years investing in a tradition of compliance to guard themselves. Disrupters, with entry to low-cost capital and few legacy property, haven’t any such constraints. In Robinhood’s case, no much less an institution bulwark than Goldman Sachs has blessed its method to enterprise by taking the lead on the corporate’s IPO. Forget orange — criminality with out consequence is the brand new black.The soul of the brand new machineRobinhood made its “prospects” really feel particular by reserving a 3rd of the providing for them. But the deeper into the insider circle (early traders and workers) you go, the extra particular (and rich) it will get.In February, RH issued $2.55 billion in tranche 1 convertible notes, that are to be exercised at 70% of the IPO value: That’s $26.60 a share vs. $38. This means the convert consumers noticed an immediate and assured 43% achieve once they awoke yesterday morning. There’s additionally $1.03 billion in tranche 2 converts that get the identical deal. In addition, 27.8 million shares are reserved for future stock-based worker compensation. That’s greater than $1 billion reserved, once more, for the actual insiders.

As for the RH customers who have been seeking to capitalize on their “head begin,” the fast 8% loss will sting. But that is what occurs when your IPO values you at 33x annual income. By distinction, Charles Schwab is value 11x income, regardless of yielding earnings 3x higher than Robinhood’s income.Pocket on line casinoIn apply, Robinhood’s actions look extra just like the dispersion of economic danger than the “democratization of finance” — form of like if a for-profit jail claimed to be “democratizing housing.” As each an app and as an funding, RH makes extra sense within the context of playing than investing. Its enterprise mannequin is determined by energetic merchants, however analysis reveals the extra energetic merchants are, the extra money they lose. Likewise, the on line casino is not making a lot off the blackjack participant who sits on the $5 desk cadging free drinks, but it surely hopes the lure of straightforward cash (and the lubrication of these free drinks) will loosen his pockets finally.

Scott Galloway

Greater playing entry is changing into a development. The unlawful sports activities betting market, estimated at $150 billion a 12 months, is quickly shifting to authorized on-line boards. You can now place a sports activities wager out of your sofa in 20 states and counting, and cellular playing apps are reaping the rewards. Since its

itemizing in April 2020, DraftKings’ inventory is up 160%. I haven’t got an issue with this, as these companies state what they’re made for: playing.Another market that is benefited from our insatiable urge for food for danger? Crypto. Robinhood caught that development early and launched crypto buying and selling to its platform in February 2018. Since then, the worldwide crypto market has grown from $450 billion to $1.9 trillion. In the primary three months of 2021, 6% of RH’s income got here from Dogecoin trades. If that feels like an unstable enterprise mannequin, belief your instincts.

RemediesHere’s what we’re saddled with: A development of corporations that prey on our monetary naiveté, with no regard for legislation or morality and infinite quantities of capital. What can we do?First, it is long gone time for the rule of legislation to reassert itself. Five years in the past, admissions to elite universities have been awash in bribery and fraud. Then the feds put some rich attorneys, traders, and tv stars in jail. Did it work? I’d enterprise that if any mother or father receives an supply of a “facet door” for their child to get into an elite college right now, the mother or father hangs up, crisply.Second, we have to arm ourselves, and significantly our younger folks, with monetary literacy. Everyone must be fluent within the fundamentals of markets and how you can construct monetary safety. My NYU colleague Aswath Damodaran believes the perfect regulation is life classes. Perhaps fundamental classes in finance (e.g., to not commerce on an app that harvests its orders for income) would reduce the ache of those classes. If we are able to supply pc science and Mandarin in colleges, we should always supply programs in monetary literacy. The English-as-a-second language course in any capitalist society must be in cash.In November 2017, Wisconsin handed a legislation requiring that private finance courses be integrated in Okay-12 curriculum. In 2019, New Jersey adopted swimsuit: Financial literacy training is now required yearly of center college. A begin.

But in response to PwC, solely 24% of millennials have fundamental monetary literacy. Meanwhile, the median age of the Robinhood consumer is 31. The firm is overlaying its bases with an investing training web site, Robinhood Learn, however that does little to nullify the toxicity of its platform.

Scott Galloway

The federal authorities hasn’t executed sufficient both. The greatest the Financial Literacy and Education Commission may give you was … one other web site. Its flagship training product, MyCash.gov, acquired a whopping 700k web page views in 2020 — lower than a tenth the variety of day by day Robinhood customers.We’ve applied insurance policies within the US which have resulted in a halving of the wealth of Americans below the age of 40 (as a share of family wealth) over the previous three many years. With a lot much less to lose, right now’s younger Americans are justifiably wanting for new asset courses and embracing volatility. Put one other means, there’s trigger for a rise up. The meals industrial advanced needs you to be fats, social media needs you to be divided, and RH needs you to imagine you may get wealthy fast by day buying and selling. Rebel.Life is so wealthy,



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