Trade Republic and Payment for Order Flow (PFOF)

This is a long read. There’s a summary at the bottom, but I hope you enjoy the ride as it took most of my Saturday (what else am I supposed to do in lockdown :joy:).

You may have seen @adam and @Viktor recently throwing punches at Trade Republic on Twitter for “obfuscating” and "concealing Trade Republic’s “true business model”.

Adam Dodds (source) and Viktor Nebehaj (translated) on Twitter (source).

The article Adam linked, We’re nothing like Robinhood, says Berlin-based broker Trade Republic, says that “when asked whether he believes this process — known as payment for order flow — to be ethical, Hecker preferred not to comment”. Christian Hecker is a cofounder and CEO of Trade Republic and made the following comment to Sifted.

“I can only say that the challenge in brokerage in the US is completely different than in Europe. Trade Republic doesn’t cooperate with any hedge fund, we’re not affiliated with anyone, and we have no shareholders.”

You could read this as him saying they don’t accept payment for order flow (PFOF), but he’s not actually saying that. Not literally anyway. So is he obfuscating or concealing the truth?

A quick search finds returns the article above, as well as a blog post from Johan Brenner who is a General Partner of investment firm Creandum. In the blog post, Backing Trade Republic — Commission free trading for everyone, Johan has the following to say about Creandum’s choice to invest in Trade Republic.

Trade Republic, like most online brokers, secures revenues through payment of order flow from trading partners. The major difference is that Trade Republic is willing to share these revenues directly with their customers, enabled through their lean and mostly automated backend/cost structure, and therefore allowing customers to trade commission free.

Even though I’d expect him to know, I’d rather hear it from Trade Republic themselves.

Trade Republic’s home page contains answers to nine questions. The question “How does commission-free trading work?” is answered as follows.

In the past four years we have built a powerful digital bank using modern technology. Like many other brokers, we receive rebates from trading partners. On this basis, we can free you from high order commissions through our efficient structures. There is only a lump-sum fee of one euro per trading transaction for processing.

Is that clear enough? I’m not sure. The Help Centre doesn’t have any more details, but the Kundenvereinbarung (customer agreement) linked off the Imprint/Impressum page does.

Aside: The French version of their website links to the German customer agreement. I wonder how non-German-speaking French customers know what they’re agreeing to?

I used Google Translate to translate the customer agreement (it can translate documents as well as text). Annex 1.2 is titled (translated) “Dealing with Conflicts of Interest” and contains the following (translated).

Trade Republic also receives payments from third parties for the execution of the securities orders (see section 4.2. Of the framework agreement). The receipt of these payments and benefits or other incentives serves to make provision and further development more efficient and high-quality infrastructures (ie in particular the application) for the acquisition, observation and sale of a wide range of financial instruments for the customer. Trade Republic publishes the receipt of the benefits to the customer annually.

The wording is a bit unclear. It may just be the translation, but let’s look further. It specifically references section 4.2 as having more details. That section is long and poorly formatted, but it’s all interesting.

In connection with the execution of securities transactions, Trade Republic can make payments from the operators of the execution venues or counterparties for execution transactions (hereinafter " execution venues") or of providers of securities piers (e.g. providers of ETFs; hereinafter referred to as " providers ") for placing orders at these execution venues or Counterparties (ie the execution of commission business) or for the acquisition of certain products from a provider Receive Trade Republic customers. These payments, for example so-called processing cost subsidies, usually amount to up to EUR 3.00 per customer order; in exceptional cases and depending on certain trading volumes up to EUR 17.60 per Customer order (as of 10/2019) (ie Trade Republic can accept a payment up to this amount for placing a customer order the place of execution or from the respective provider). The amount of the payments depends on the individual case agreement with the execution venue or provider and the overall agreement on the execution venue in defined time segments processed turnover. This payment is acceptable. Trade Republic uses payment to give customers the most cost effective and to offer high-quality technical services under this contract. The customer agrees that Trade Republic collects and is allowed to keep these payments. The customer and Trade Republic meet those of the legal Regulation of the right of agency (§§ 675, 667 BGB, 384 HGB) deviating agreement that a claim of Customers against Trade Republic on surrender of the payments does not arise. Without this agreement, Trade Republic would - subject to the applicability of the right of agency to the services of Trade Republic under this contract - issue the payments to the customer.

I’m not a lawyer, but this appears to be where the customer agrees that Trade Republic being paid between €3.00 to €17.60 by “operators of the execution venues or counterparties” for executing their orders with that execution venue or provider. The customer agrees Trade Republic is allowed to keep the payments to use to give customers the most cost effective and high quality services. Interestingly, it specifically says that if the agreement didn’t exist, Trade Republic would issue the payment to the customer.

So yes, Trade Republic’s CEO is obfuscating and concealing the truth. They just never call it ‘payment for orderflow’ and they always try to justify it by linking it to providing their service. If only there was another business model that didn’t involve conflicts of interest.

Speaking of which, Freetrade’s Conflicts of Interest policy, which is directly linked from the website’s footer, explicitly states the following.

We do not receive financial or non-financial benefit from any trade execution venues or counterparties in return for sending our customers’ orders to them (sometimes known as ‘payment for order flow’).

Is Trade Republic’s PFOF legal?

Again, I’m not a lawyer, but I had a look anyway.

Even though Trade Republic is in Germany, I’m starting in the UK. In December 2017, the FCA published an open letter regarding Payment for Order Flow (PFOF). They seem to do this regularly and address the letters “Dear CEO”. In short, this letter restates that “PFOF arrangements introduce a conflict of interest which is likely to cause harm to clients and markets”. It then goes on the talk about MiFID II, which is a revision of MiFID (“Markets in Financial Instruments Directive”). The FCA states that MiFID II “further restricts the practice of PFOF” and “strengthens the conflicts of interest requirements”.

The third and final section of the letter contains three examples of where companies could be trying to avoid MiFID II’s requirements. Here’s the first example:

Linking charges to market makers for non-execution services, such as research products or market analysis software, to the amount of business transacted, in an attempt to replicate the PFOF previously received, or insisting that market makers subscribe to such non-essential services to continue to see the broker’s flow.

Of course, the FCA doesn’t regulate Trade Republic, so we need to look further. At least now we know MiFID II is what should be preventing PFOF.

Does MiFID II affect Trade Republic?

EU directives like MiFID (2002/92/EC) and MiFID II (2014/65/EU) are legislative acts that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to devise their own laws on how to reach these goals. The EU provides a website where you can view all the directives and their national transposition details and dates. For MiFID II, that can be found here where it says Germany published their relevant law on 24/06/2017. It usually says if a directive is only partially implemented, which it doesn’t this time, so German companies like Trade Republic should effectively be regulated by MiFID II.

What does MiFID II actually say about PFOF?
You can find the whole directive here. Of particular interest Article 27, “Obligation to execute orders on terms most favourable to the client”. The whole article is worth reading, but paragraph 2 says the following.

An investment firm shall not receive any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or execution venue which would infringe the requirements on conflicts of interest or inducements set out in paragraph 1 of this Article and Article 16(3) and Articles 23 and 24.

This paragraph references Article 23, which is important because it says that if the broker can’t remove conflicts of interest, they must disclose them to the customer. This is probably why the Trade Republic customer agreement discloses this conflict and says the customer agrees to it.

In my intepretation, MiFID II clearly tries to prevent payment for order flow, but doesn’t ban it. Instead, it seems to be allowed as long as it’s disclosed to the customer and the customer agrees to it (even if it’s in a language they can’t read, I guess).

Are Trade Republic not abiding by MiFID II?
I don’t know. I’m not a lawyer. It seems like they are because they’re disclosing the conflict in their customer agreement. However, it’s not MiFID II they need to follow. Instead, they need to follow Germany’s national transposition of the law (i.e. Germany’s laws that implement EU directive 2014/65/EU, aka MiFID II.

I saw someone claim that Germany has an exception, or that PFOF is legal in Germany.

What do Germany’s laws say?
Going back to the national transposition page it says Germany’s relevant laws were published in “Bundesgesetzblatt Teil 1 ( BGB 1 ) ; Number: 39 ; Publication date: 2017-06-24 ; Page: 01693-01821”. This is the Federal Law Gazette, and we’re looking for pages 1693-1821 of issue number 39 of Part 1. They’re all available online for free dating back to 1949, so it was easy to find here. Of course, it’s in German, so I punished Google Translate by asking it to translate the almost 200 pages.

This gazette appears to contain changes to laws. What a thrilling read. Luckily I can just search for “remuneration” and find interesting things. Specifically on page 1744 I found:

§ 33a is amended to § 82 and as follows:

e) Paragraph 8 is worded as follows:

“(8) An investment services company both for the execution of customer orders at a specific trading place or place of execution as well as for the Forwarding customer orders to one specific trading venue or execution place neither a remuneration nor a discount or accept a non-monetary benefit, if this is a violation of the requirements according to § 63 paragraphs 1 to 7 and 9, § 64 Paragraphs 1 and 5, Sections 70, 80, paragraph 1, sentence 2 Number 2, paragraphs 9 to 11 or paragraphs 1 to 4 would represent.”

The translation seems poor, but the wording is really similar to Article 27 of the directive. The above comes from Article 3 “Further amendments to the Securities Trading Act”. In German, Securities Trading Act is Wertpapierhandelsgesetz. What a fun language.

The Wertpapierhandelsgesetz is from BaFin, the “Federal Financial Supervisory Authority”. Thankfully, they publish the Securities Trading Act in English: BaFin - Acts - Securities Trading Act.

Looking back, we saw that “§ 33a is amended to § 82” which apparently means “section 33a was changed and also renamed to be section 82”. It doesn’t appear to have been renamed after as Section 82 is Best execution of client orders.

Paragraph 8, now in English straight from BaFin, states:

(8) An investment services enterprise may not receive any remuneration, discount or non-monetary inducement either for executing client orders on a particular trading venue or for routing client orders to a particular trading or execution venue that would infringe the requirements under section 63 (1) to (7) and (9), section 64 (1) and (5), sections 70, 80 (1) sentence 2 number 2, subsections (9) to (11) or subsections (1) to (4).

That’s the same as the directive, but has a lot more references. Section 70 covers “inducements and fees”. An inducement is what it sounds like: “a thing that persuades or leads someone to do something”. For example, a payment for order flow. This section says:

(1) 1An investment services enterprise may not, in relation to the provision of an investment services or ancillary investment services, accept any inducements from third parties or provide any inducements to third parties that are not clients of this service or do not act on behalf of the client, unless

  1. the inducement is designed to enhance the quality of the service to the client and does not impair the proper provision of the service in the best interest of the client within the meaning of section 63 (1), and
  2. the existence, nature and amount of the inducement or, where the amount cannot be ascertained, the method of calculating that amount, is clearly disclosed to the client in a manner that is comprehensive, accurate and understandable, prior to the provision of the investment service or ancillary investment service.

There’s the answer as to why Trade Republic always say their PFOF is intended to improve their service; German law says that’s the only reason they’re allowed to accept the payment. It’s also the reason it’s disclosed in such detail (i.e. the amounts).

Section 70 goes on the say “Investment services enterprises must hold evidence that all inducements paid or received by them are designed to enhance the quality of the relevant service to the client” which would be interesting to see. To me, this seems like a fairly easy loophole to make use of.

What? Can you summarise?

  • MiFID II bans unless you disclose it to the customer.
  • Germany’s Securities Trading Act (which transposes MiFID II into German law) bans PFOF unless you:
    1. Disclose it to the customer (including the amount, or calculation & subsequent report), and
    2. The payments go toward improving the service for the customer (which you must show on request).
  • Trade Republic seem to be following the law.

My opinion

PFOF is clearly a conflict of interest. MiFID II, German law, @adam, @Viktor, and the FCA says so too. The fact the Trade Republic CEO doesn’t comment on whether it’s ethical is telling. The fact he goes on to make it sound like they don’t take PFOF is misleading.

I for one am looking forward to Freetrade’s launch in Germany and France.


A very interesting read @zaccharles

Thanks for taking the time. A clear conflict. Even if they do say it helps improve their customers service.


That’s a top piece of work. Very well researched. :clap:


Excellent research - can you speak German now?




Wonderful research @zaccharles

One wonderful thing for FT about competing brokers using a PFOF business model is that they won’t scale as well as FT internationally. I believe Robinhood cancelled their UK market largely because PFOF is illegal in the UK, so one would expect Trade Republic not to enter the UK also, leaving a massive market share for FT here. A very quick google search suggests that PFOF is illegal in Australia too, again leaving a huge market opportunity open for FT in their next territory.


The analysis done here is pretty good and sums it up correctly.

I am a law student in Germany so I can say that these Google Translations are pretty misfortunate, but they do get the point across.

It is true that PFOF is legal in Germany as long as it is clearly disclosed to their customers as a possible conflict of interest and the amount of recieved funds is disclosed at the end of the year.

But Trade Republic isn’t hiding the fact that they do PFOF at all and are not sugar coating it, or at least they haven’t before the whole Robinhood debacle.

In October 2020, Stiftung Warentest, an independent consumer organisation which is focused on testing and investigating products and goods on their claims and actual quality, has done research on free trading apps, one of which was Trade Republic too (Neobroker im Vergleich | Stiftung Warentest) (paywall).There, they also managed to get a direct statement from TR in which they openly admitted to receiving “back payments” (Rückvergütungen) from their stock exchange.

  • Trade Republic Bank uses its cost savings in combination with these reimbursements to customer’s advantage. This creates a disruptive business model: the mobile and commission-free securities trading. For the processing only a foreign costs flat-rate fee of €1 per trade is charged. Trade Republic has a German banking license as a securities trading bank and is supervised by the Federal Bank (Bundesbank) and Federal Agency for Financial Supervision (BaFin). In addition there is a cooperation with the electronic trading system LS Exchange operating at Hamburg Stock Exchange. The market price quality for securities and ETFs is supervised by the stock exchange.

  • (Die Trade Republic Bank nutzt ihre Kosteneinsparungen in Kombination mit dieser Rückvergütung zum Vorteil der Kunden. Daraus entsteht ein disruptives Geschäftsmodell: der mobile und provisionsfreie Wertpapierhandel. Für die Abwicklung wird lediglich eine Fremdkostenpauschale von einem Euro pro Handelsgeschäft erhoben. Die Trade Republic hat eine deutsche Banklizenz als Wertpapierhandelsbank und wird von der Bundesbank und BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht) beaufsichtigt. Hinzu kommt die Kooperation mit dem an der Börse Hamburg betriebenen elektronischen Handelssystem LS Exchange. Die Kursqualität für Aktien und ETFs wird börslich überwacht.)

From this it is obvious that Trade Republic is desperately trying to save their image in light of current events and have not lied about PFOF in the past and are not lying about PFOF now, they just aren’t disclosing it by its official name. And as long as everything is legal, there are no problems with it either.

To that, using PFOF as a trading bank is very much different from what Robinhood did in the US, which is trading securities with hedge funds directly, without using a stock exchange at all.


To add to this, almost all trading platforms in Germany trade on stock exchanges that offer PFOF but still charge their customers €5-15 per trade, which would actually be more critical regarding the legality of PFOF if the customer still pays high fees. These are still completely legal though.


Furthermore, there has been a false info spread by @doddsie/ @adam on Twitter (, which ignores the biggest difference between Citadel and Robinhood and L&S and Trade Republic:

  • Citadel has two branches - Citadel LLC (hedge fund) and Citadel Securities LLC (market maker). This means there is a conflict of interest at the core of the ownership structure of Citadel Securities as there is no guarantee the flow of information is prevented between the market making and the hedge funding branches.

  • As opposed to that constellation, Lang & Schwarz AG is a company which emits derivatives as their core business and owns L&S Exchange (at Hamburg Stock Exchange) as their trading exchange and Lang & Schwarz TradeCenter AG acts as a market maker at this exchange.
    So in this situation, there isn’t a conflict of interest like with Citadel, where one company de facto owns large amount of shares in their own interest while at the same time acting as a market maker/trade exchange. Yes, derivatives are a type of shares as well, but their worth is not directly affected by L&S emitting them.

So yes, PFOF is disputable, but Trade Republic’s situation is not directly comparable to Robinhood’s as there is no conflict of interest on the market makers side.



Isn’t it true that a majority of RH’s revenue was made of order flow payment? I don’t know if TR would publish that on their financials?

I think Adam and Viktor probably just want the debate to continue post-GME into who benefits from all these practices and whether retail traders are getting a raw deal (and ready for an FT expansion into Germany). If MM have prior knowledge of trades can’t they still work the market to their own benefit?


What I said is factually correct, what the journalist wrote is factually incorrect.

Citadel certainly has a conflict of interest between its market making business and its proprietary trading arm, which is has been fined by the SEC for in the past. Most large market participants (eg big banks) have this conflict of interest as well. I liked Ken Griffin’s suggestion to US legislators to change the rules to encourage more retail trading to be done on exchanges.

But I would still argue Robinhood’s (current) set up is much better for customers than Trade Republic.

Robinhood (if you believe them) makes a panel of market makers compete for customer orders on price, and demands the same kickback from all of them. So sort of a level playing field to get best ex for customers.

As far as I know, Trade Republic sends 100% of their orders to the same counterparty, which pays for the flow. There is no competition to get the best price for customers. L&S is not a ‘real’ stock exchange. They borrow their regulatory cover from the Hamburg exchange, which itself is a minor venue.

What happens is they use the observable price on the ‘real’ stock exchange as benchmark for the worst price they can give that is defensible from a best execution point of view. There is no incentive for price improvement. The incentive is for L&S to give the worst price they are allowed.

As a customer, you will almost certainly get better execution with Robinhood’s setup than Trade Republic’s. But if Robinhood told their panel of market makers that they did not want PFOF and just to compete on true best price, then their customers would get better execution prices. It’s pretty simple math.

The only way to do it properly is to act in the best interests of your customers and seek best execution for them, without any inducements as to where the order goes.


I am a TR user in France and before this thread had no idea about the fact that they are selling the order flow.

It does make them similar to RH and it is hidden in the legalese in T&C speaking from an an average customer viewpoint.

Don’t see any false info spread when both of the companies have the PFOF as their main source of revenue.

Shareholders issue you mention is a whole other topic.

Also with TR’s set up hard to say the FX conversion cost

Would be interesting to see how prices compare after FT’s launch in the same countries

One would not expect the average customer to know the level of detail exposed above by @adam


This research and discussion in one image.


I read a very thorough explanation of the theoretical benefits of PFOF on the Andreessen Horowitz blog which they published last week here:

What I don’t understand - and I may be missing something here? - is that the AH partners who wrote this post are looking at market makers and high frequency traders as distinct, even competitors. When they are not competing, but sharing better real-time market sentiment data, doesn’t this give the market maker a structural advantage in their HFT business via significantly better-informed algos? They don’t need to front-run orders, but can make many other low-latency high-frequency investment decisions with this trade volume (and corresponding indicator) advantage. With the right AI to power their trading, PFOF could even be a loss-leader for them given the HFT benefits.

Isn’t that the real story here, more than whether/not the market makers are getting the best prices for their customers?

Andreessen Horowitz is a large investor in Robinhood, so it’s not surprising to me that the overall message is in support of PFOF.

They do a good job of explaining that market makers profit from the spread and beneficial price changes. I think it’s easy to see why a market maker would offer part of the spread as inducements to brokers for executing client trades with them. They may also offer an inducement to get out of a bad situation sooner.

Here’s an extract from Robinhood’s Stock Order Routing article (my emphasis):

Are you incentivized to route orders to one market maker over another?

No. To operate a fair system, we don’t take rebates into consideration when we choose the market maker that executes your order. Also, all market makers with whom we have relationships pay us rebates at the same rate, which means we aren’t incentivized to send orders to any one specific market maker.

How do you structure the rebates you receive from market makers?

We earn a percentage of the bid-ask spread, or the difference between the highest price to buy (bid) and the lowest price to sell (ask) the equity, at the time of execution. Spread is determined by the National Best Bid and Offer (NBBO) published spread.

In short, Robinhood gets the same PFOF rate from all the market makers they cooperate with. Therefore, it makes sense that they say they don’t consider it when routing orders. It’s also true that they benefit more when the spread is larger. So how do they decide who executes a client’s order?

How do you decide where to route orders?

We have relationships with a number of market makers in an effort to optimize speed and execution quality. Of these market makers, our system automatically routes orders to the market maker that’s most likely to give you the best execution, based on historical performance.

This means Robinhood aren’t going out to their partner market makers, collecting prices, then choosing the best one for the client. How do they know the client is getting the best price? It seems that they don’t.

The post talks about the fact a market maker can choose to sacrifice some more of the spread profit in order to offer the client a better price. That is, they’d buy the client’s shares for more than the best bid price, or sell to the client for less than the best offer price.

But what incentive do they have to do that if they’re not actually being directly compared with others, as in Robinhood’s case? Historic data apparently feeds into the algorithm, so you could argue they’d eventually lose Robinhood’s order flow, but the market maker could run an algorithm that, for example, offers better prices when there’s less spread to eat into and offers national best prices when there is more profit to be made.

In Trade Republic’s case, where there is only one execution venue, what incentive, at all, do they have to ever offer a better price?

In any case, if a market maker is sharing the spread with the broker as payment for order flow, there is less spread to sacrifice toward offering a better price to the client. Maybe there isn’t any left at all.

In the worst case, a broker would choose a trading venue based on PFOF. That venue may just offer national best price whereas another might have sacrificed some spread to the client to be competitive. If PFOF didn’t exist, price would be the primary thing market makers competed on, and inducements wouldn’t eat into the spread leaving more room to move on price, which would be better for clients.

Lastly, brokers receiving PFOF have an incentive to encourage clients to trade as much as possible. The same could arguably be said about a FX fee (thoughts @adam ?) but whataboutism doesn’t make it go away.

This is all just my opinion and I’m not an expert.


This is a great marketing weapon for going head-to-head with Trade Republic in the EU :ok_hand:


I don’t mind paying an FX fee, at least it’s easy to understand, also FT needs to make money somehow, and I’d rather it’s with a fixed percentage on each trade.

My problem with PFOF is that it’s more complex and harder to quantify exactly the how much it costs each time

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The SEC found that $34.1m was taken off the table for retail investors (even including the commission free structure).

They would have been better off paying for trades with other brokers and receiving a better spread.

I know a lot of people on the forum found the FT Plus ‘paywall’ model controversial. But I see it as being the most transparent / sustainable model in comparison to trade commission and other disruptive brokers models. FT have differentiated and are innovating in this area. I think so anyway…


So I guess that Payment For Order Flow sometimes improves the price a buyer vs the one they’d have got on the exchange, and sometimes it worsens the price.

One of Matt Levine’s recent newsletters was - to this naive retail investor reader - very interesting on PFOF. A bit on the mechanics of PFOF:

But! The broker realizes, look, all these people who want to buy shares could be matched up with all these people who want to sell shares. I don’t have to pay a fee to the exchange, the buyers don’t have to pay $58.25, and the sellers don’t have to get $58. The buyers could pay $58.15 and save 10 cents, the sellers could get $58.10 and make an extra 10 cents, and I could keep 5 cents (and avoid the exchange’s fee) for my trouble. That’s a good deal for everyone!

And a bit on whether PFOF has bad effects:

Otherwise normal people will start out mainstream explainer articles by saying, like, “Robinhood sells your order to Citadel so Citadel can front-run it.” No! First of all, it is illegal to front-run your order, and the Securities and Exchange Commission does, you know, keep an eye on this stuff. Second, the wholesaler is ordinarily filling your order at a price that is better than what’s available in the public market, so “front-running”—going out and buying on the stock exchange and then turning around and selling to you at a profit—doesn’t work.[5] Third, because retail orders are generally uninformative, the wholesaler is not rubbing its hands together being like “bwahahaha now I know that Matt Levine is buying GameStop, it will definitely go up, I must buy a ton of it before he gets any!”[6] The whole story is widely accepted but also completely transparent nonsense.

Perhaps this argument hinges on how often and by how much the wholesaler is “ordinarily filling your order at a price that is better than what’s available in the public market”. It’s 5 Feb if you get his email, or online here, though you might need a Bloomberg sub to read.

Regardless of how PFOF does(n’t) work, I agree that a more transparent business model is clearer to understand.

It’s not PFOF that somtimes improves the price. It’s the market maker supposedly competing on price. If they didn’t have to cut their profit margin to pay for order flow, they could instead cut it to offer a more competitive price. PFOF at best means prices are less competitive, and worst means your order got routed to a market maker who had no intetion of competing on price.

I’m fairly sure that in the US and EU, market makers can’t offer worse prices than you would have got essentially directly on an exchange. I believe the reason the SEC found that Robinhood deprived customers of $34.1m is that they routed customer orders to market makers that weren’t offering the best price. That not-best-price may still have been better than the “national best price”, but could have been even better with another market maker.