This connected but decentralized market struc-
ture is a result of Regulation NMS (National Mar-
ket Structure) (Nanex13) which was mandated by the
US Congress and implemented after 2005. Following
(Maese14) the bitcoin network is actually reminiscent
of a network which was initially created to imple-
ment NMS regulations. No further details are given
however we read that bitcoin technology is “brilliant”
and maybe a ”kind of value transfer network that you
could dream about creating” for the stock markets ”if
existing businesses had the luxury of a fresh start”, cf.
(Maese14).
In the US there are over 50 liquidity pools (again
called “nodes”). Under regulation NMS, there are
14 nodes which are Self Regulatory Organizations
(SROs), or the “lit exchanges” which “publish” their
data feeds. All nodes including these exchanges
themselves have to check the best prices on the 14
official exchange nodes.
In order to complete the whole picture, these
quotes are aggregated at the Consolidated Quote Sys-
tem (CQS) cf. (Nanex13). Actually the markets check
CQS for best prices which is called National Bid or
Offer (NBBO). Once a match happens on one of these
nodes, the information about it is “reported on” the
Consolidated Trade System (CTS) where all trades
are aggregated. Everything is reported immediately
with the timestamp of the executing node in UTC
time. The combination of CQS (quotes) and CTS (ex-
ecuted trades) is sometimes called the SIP.
2.2 Timestamps
At microsecond levels accuracy issues around hard-
ware, software and application timestamps become
relevant. Some of the recent controversies (Lewis14;
Nanex13) in equities markets stem from intricacies in
inner workings of this system.
The nodes provide direct market data feeds which
consists of the quotes at those specific nodes. Some
traders (actually machines) have access to these direct
data feeds. Other traders access quote data through
CQS. Direct data feeds allow to obtain the informa-
tion faster, a few milliseconds before the SIP data.
At one moment the public data feed (CQS) had a de-
lay of 22 milliseconds versus the direct (paid) feeds
which was claimed contrary to the NMS regulations,
cf. (Nanex13). Direct data feeds cost considerably
more, in tens of thousands of $ per month in direct and
indirect costs including the necessity to build special
equipment, employing network engineers, large telco
fees. 2.5 million subscribers pay the exchanges about
$500 million each year to obtain such low latency data
cf. (Nanex13).
In these markets, timestamps are very important:
the first buyer gets the share at one price, another gets
it later at another price. The order of the execution of
transactions is crucial. Timestamps are generated by
14 trusted nodes or exchanges which are expected to
be honest. Their public version, the SIP timestamps
have lower precision and could be less accurate, cf.
(Nanex13). An interesting question is whether it is
possible to manipulate these timestamps for profit.
We are not aware of such scenarios.
This question will come back in bitcoin. No one
is trusted in bitcoin and in Section 4.1 we argue that
bitcoin needs some “peers” to certify timestamps of
other network peers. In bitcoin the order of process-
ing the transactions matters less, except in situations
of double spending. Unhappily transactions have NO
timestamps in bitcoin, the founders of bitcoin simply
forgot to implement any(!), cf. (Courtois14). Thus it
becomes difficult to distinguish between various sit-
uations and take reasonable well-informed decisions
which is a crucial question, cf. Section 4.
2.3 Validation
In these decentralized US equity markets there is a
process of “policing” and checking for the good be-
havior which is very different from checks which
need to be done by bitcoin miners. for the correctness
of the final bitcoin blockchain. There is a price time
priority for matching quotes. This means that quotes
match at first come first serve basis at the best price.
Now at a certain moment there is (or there can be)
a demonstration of the sequence of actions described
above to regulators and clients and verification that
trades were executed at the best price on the 14 ex-
changes.
2.4 Secure Property Transfer
There isn’t just one way to build decentralized finan-
cial systems. Timely decision making is crucial/ Bit-
coin system is somewhat fundamentally simpler than
equities trading. There is no matching of orders, there
is no double-entry bookkeeping. Yet it is all about
a some form of having a property register owned by
many participants with some degree of network neu-
trality (fairness in execution). Bitcoin blockchain is
a major innovation which could in fact also be used
to implement a similar concept of “Value Transfer
Networks” for the stock markets cf. (Maese14).
We see that the US equities markets are decentral-
ized and that “nodes” have obligation of some form of
“market neutrality”: best effort to find the best price
for customers on 14 nodes. In bitcoin we have the
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