# DIVISION OF ECONOMIC AND RISK ANALYSIS1

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Asec%3A6aebd220700f155a

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

MEMORANDUM
FILE
TO:
DIVISION OF ECONOMIC AND RISK ANALYSIS1
FROM:
SUBJECT: CORNERSTONE ANALYIS OF THE IMPACT OF THE
OPTION PENNY PILOT PROGRAM ON MARKET QUALITY
DATE:

DECEMBER 18, 2017

The Division of Economic and Risk Analysis contracted with Cornerstone Research
(“Cornerstone”), an economic and financial consulting firm, to conduct analyses related to
investigating the effects on market quality of the continuing pilot program that allows certain
exchange-traded options to be quoted in reduced price increments2 (“Option Penny Pilot” or
“Pilot”). Cornerstone’s analysis uses quoted and effective spreads as measures of market
quality.3 Effective and quoted spreads are frequently used as measures of trading costs and are
especially useful in assessing overall market quality for retail investors.4 The Division believes
that the methodology employed by Cornerstone in the analysis is appropriate to address the
questions presented and agrees with the conclusions drawn by Cornerstone based on that
analysis.
Main Finding:
The Cornerstone analysis finds that inclusion in the Pilot is associated with a statistically
significant decrease in effective and quoted spreads for the most liquid options - those with
trading volume in the top five percent of the universe of all listed option classes.5 However, for
less liquid options, the results do not suggest that inclusion in the Pilot has a significant effect on

1

This is a memorandum by the Staff of the Division of Economic and Risk Analysis of the U.S. Securities and
Exchange Commission. The Commission has expressed no view regarding the analysis, findings or conclusions
contained herein.
2
More specifically, the Pilot specifies that options trading at less than $3.00 have trading increments of one cent,
while those trading at $3.00 or more have trading increments of five cents. Options not in the Pilot have
corresponding minimum price increments of $0.05 for options trading below $3.00 and $0.10 for options above
$3.00. The Pilot makes an exception for options on the QQQQ, IMW and SPY which trade at or above one cent
increments, regardless of price level.
3
In Cornerstone’s analysis, spreads are volume-weighted across different trades in an option series, and then
equally weighted across option series, in order to obtain spreads for the option-class day. Those spreads are then
equally weighted across different days in the pre-event month and the post-event month, respectively, in order to
obtain option-class month observations.
4
“Decimal Pricing Has Contributed to Lower Trading Costs and a More Challenging Trading Environment,” GAO
report, May 2005, at 3 (available at http://www.gao.gov/new.items/d05535.pdf).
5
Note that Cornerstone’s analysis on option classes on common stock incorporates data on 3,833 option classes and
1,331,185 class-day observations.

market quality. Cornerstone reports that the option classes added to the Pilot were mostly
chosen from the most liquid and heavily traded option classes.6
Comparison to Analyses of Self-Regulatory Organizations:
Several Self-Regulatory Organizations (SROs) conducted analyses of the effects of the Options
Penny Pilot. The SROs made these analyses available on their websites.7 The reports of the
SROs focus on the activity on their own exchanges; none of the reports takes a holistic view of
the Pilot on all exchanges. Also, their analyses typically did not use control samples. Finally,
the most recent of the publicly available reports from an SRO dates from 2013, and thus the
Cornerstone analysis covers more recent time periods.8 However, the SRO analyses generally
agree with the conclusions drawn from Cornerstone’s analysis that the Pilot was associated with
a narrowing of spreads.
Analysis:
Cornerstone’s analysis uses quoted and effective spreads as a measure of market quality, and it
employs two methodologies.
The first methodology uses a univariate “difference-in-differences” approach, in which the
changes in quoted and effective spreads during the Pilot for options classes included in the Pilot
are compared to contemporaneous changes in spreads for a control sample of option classes that
were not included in the pilot. Options classes included in the control sample were matched on
option class volume and underlying market capitalization. This sample was referred to as the
“matched sample”.
The second methodology uses multivariate regression models to explain variation in the quoted
and effective spreads before and after option classes were added to the Pilot. These models
include independent variables to control for other factors that can impact spreads, including
option volume, underlying stock volume, and underlying stock volatility.
Using data on options on common stocks added to the Pilot between January 26, 2007 and
January 5, 2016,9 both methodologies have similar findings. The “difference-in-differences”

6

Although some of the original thirteen options were not among the most liquid, most heavily traded options, the
order approving the commencement of the penny pilot program describes the selection of the initial option classes
as follows; “The Commission believes that the thirteen options classes to be included in the penny pilot program
represent a diverse group of options classes with varied trading characteristics. This diversity should facilitate
analyses by the Commission, the options exchanges and others.” See Securities Exchange Act Release No. 55156
(January 23, 2007), 72 FR 4759, 4760 (February 1, 2007) (SR-NYSEArca-2006-73) (Order approving a penny
pilot program on NYSE Arca).
7
These data and analyses are available online at https://www.nyse.com/markets/amex-options/reports ,
http://www.ise.com/options-penny-pilot , https://www.cboe.org/generalinfo/pdfframed?content=/hybrid/cboepennypilotreport03042008.pdf&section=SEC_HYBRID_HOME&title=CB
OE%20Penny%20Pilot%20Report and http://boxoptions.com/regulatory/pilot-reports/
8
http://www.ise.com/assets/files/investors/Topaz_Penny_Pilot_Report_15.pdf
9
Results for 693 option classes on ETFs were generally similar to option classes on common equity.
2

tests find that, compared to the control sample, inclusion in the Pilot is associated with a
decrease in effective spreads of 3.5 cents and a decrease in quoted spreads of 5.1 cents.
Similarly, using the same matched sample, the regression model finds that the Pilot is associated
with a decrease in effective spreads of 3.6 cents and a decrease in quoted spreads of 5.2 cents.
These results are statistically significant.
Cornerstone reports results separately for sub-periods 2007-2009, 2010-2011, and 2012-2015.
The results are generally weaker in both statistical significance and in economic magnitude for
the period 2012-2015. One potential explanation advanced by Cornerstone for the smaller
decrease in spreads for later additions to the Pilot is that the benefits of the Pilot are most
pronounced for options on larger stocks or for option classes with the highest trading volume,
and to the extent that the later additions to the Pilot tend to be smaller stocks with lower-volume
options, there would be smaller declines in spreads for the later additions. Also, the 2012–2015
results are based on a relatively small sample of options.
One caveat to the results of the analysis that Cornerstone emphasizes is that the option
exchanges have a different fee structure for classes within and outside the Pilot. Cornerstone’s
analysis does not try to examine whether the improvements in market quality could be attributed
only to the Pilot, or also to the differing fee structures. However, Cornerstone also notes that the
average declines in execution costs for the most liquid option classes appear to be substantially
higher than the potential impact of any fee adjustments.
As option classes added to the Pilot were mostly the most liquid and heavily traded, Cornerstone
also includes analysis specifically aimed at testing whether the Pilot contributed to improved
market quality for less liquid option classes. The analysis uses more recent data, from February
2016, in order to allow the testing of the impact of the Pilot on option classes that may have been
more liquid when they were originally added to the Pilot, but that over time became less liquid.
Due to the low liquidity of these option classes, had the inclusion decision been made in
February 2016, they may have not been selected for inclusion in the Pilot.
However, Cornerstone’s analysis is neither consistent nor inconsistent with the proposition that
additional low volume option classes would benefit from pilot inclusion.10 Compared to
samples of non-Pilot options matched on option class volume, underlying market capitalization,
and underlying price, the results indicate evidence of statistically significant reductions in
quoted and effective spreads for the top two quartiles, by trading volume, of option classes
included in the Pilot. These option classes have trading volume in the top 5% of the universe of
all listed option classes. While Cornerstone also finds reductions in spreads for the bottom two

10

Also, there exist some option classes with liquidity equal to that of those in the Pilot, but they are not in the Pilot
because they did not meet the Pilot requirements at the time a replacement class was being added to the Pilot.
Some of these are included in the controls used for the Third and Fourth Quartile in Table 22 of Cornerstone’s
research, described as “Number of Clusters for Matching with Replacement”.
3

quartiles of option classes included in the pilot, these reductions are generally not statistically
significant.
Conclusion:
The evidence Cornerstone presents suggests that the existing Pilot program has resulted in
improvements in market quality (as measured by quoted and effective spreads) for the Pilot
option classes. Cornerstone’s research does not provide any clear evidence that expanding the
Pilot to include lower-volume options would result in similar benefits. While noting that the
analysis does not control for different fee structures that apply to option classes included and
excluded from the Pilot, Cornerstone asserts that the estimated reduction in execution costs for
option classes within the pilot appear to be substantially larger than the potential impact of fee
differentials.

4

MEMORANDUM

DATE:

July 3, 2017

TO:

Division of Economic and Risk Analysis

FROM:

Stewart Mayhew, Cornerstone Research

RE:

Analysis of the Impact of the Option Penny Pilot Program on Market Quality

Executive Summary
This memo summarizes research requested by the staff of the Commission’s Division of
Economic and Risk Analysis (DERA) under the terms of contract SECHQ1-16-C0024 with
Cornerstone Research.1 This research relates to an ongoing pilot program that, since 2007, has
allowed certain exchange-traded options to be quoted in reduced price increments (“Option
Penny Pilot” or “Pilot”). DERA staff requested an analysis of the impact of the Option Penny
Pilot on market quality, as part of an effort to evaluate the efficacy of the program. The current
memo summarizes our research investigating the extent to which inclusion in the Pilot impacts
measures of market quality. The results of this research should aid the staff of the Commission
as it seeks to evaluate the overall impact of the Pilot, and as it makes decisions regarding whether

1

The analysis summarized in this memo was undertaken by a team of researchers under the direction of Dr. Stewart
Mayhew at Cornerstone Research. The team also included Dr. Amber Anand of Syracuse University, Dr. D.
Timothy McCormick, and the staff of Cornerstone Research. The findings presented herein are results of analysis
performed by the research team in response to specific requests and questions from DERA staff. This memo does
not seek to offer any policy recommendations, and should not be construed as an endorsement by the authors or by
Cornerstone Research of any particular policy alternative. Any views and interpretations expressed in this memo are
solely those of Dr. Mayhew, Dr. Anand, and Dr. McCormick, who are responsible for the content, and do not
necessarily represent the views of Cornerstone Research.

the program should be made permanent and/or whether the program covers the appropriate
number of option classes.
The research summarized herein encompasses the addition of option classes to the Pilot
over an eight-year period between January 26, 2007 and January 5, 2016. It analyzes the impact
of addition to the Pilot on quoted and effective spreads, while attempting to control for other
factors that influence spreads and for any selection bias that may influence the addition of certain
option classes to the program.
Section I of this memo provides a brief overview of the background of the Pilot,
including the timing of when new option classes were added. Section II describes the data used
for the analysis.
Section III reports summary statistics for option class volume, underlying stock volume,
and underlying market capitalization for option classes already in the Pilot, new classes selected
for inclusion in the Pilot, and option classes not in the Pilot, as of each addition date (“event
date”). The option classes in the Pilot and those selected for inclusion tend to have significantly
higher trading volume and tend to be on underlying stocks with higher market capitalization
compared to classes not participating in the Pilot.
Section IV provides additional detail regarding the construction of control samples and
reports summary statistics for the control samples.
Section V presents results of univariate “difference-in-differences” tests, which compare
changes in quoted and effective spreads after option classes are added to the Pilot to
contemporaneous changes in spreads for a control sample of non-switching option classes
(matched on option class volume and underlying market capitalization). The difference-indifferences results (presented in Table 5) indicate that inclusion in the Pilot is associated with a
2

decrease in dollar effective spreads of 3.5 cents and a decrease in dollar quoted spreads of 5.1
cents. These decreases were found to be statistically significant at the 1% confidence level, and
similar results were found for relative spreads. Results are also reported separately for
subperiods 2007–2009, 2010–2011, and 2012–2015. The average decline in spreads was smaller
for the most recent additions to the Pilot in 2012–2015, although this group has relatively few
observations. The decline in spreads is found to be robust for option classes with different levels
of underlying market capitalization (Table 6) and option class trading volume (Table 7).
Section VI analyzes additions to the Pilot using a multivariate regression approach
designed to control for other factors that can impact spreads, including option volume,
underlying stock volume, and stock volatility. This analysis confirms that inclusion in the Pilot
is associated with a statistically significant decline in effective spreads and quoted spreads,
although the estimated magnitude of the effect varies somewhat, depending on how the model is
implemented. When the regression model is estimated on the entire universe of listed options,
the results indicate that inclusion in the Pilot is associated with a decrease in effective spreads of
8.8 cents (Table 13) and a decrease in quoted spreads of 16.1 cents (Table 14). When the model
is estimated only on the matched sample described in Section IV, the Pilot is associated with a
decrease in dollar effective spreads of 3.6 cents (Table 15) and a decrease in dollar quoted
spreads of 5.2 cents (Table 16). Similar results are found for percentage spreads. The decline in
effective spreads is found to be largest in the 2010–2011 subperiod, and smallest for the most
recent additions in 2012–2015. In some specifications, the effect of the Pilot program is found to
be close to zero and not statistically significant for the 2012–2015 subperiod. We reiterate the
caveat for the 2012–2015 results that they are based on a relatively small sample of switching
options.
3

Section VII explores further whether the Pilot is contributing to an improvement in
market quality for the least liquid option classes, a question that is significant if the Commission
staff wishes to consider whether penny quoting should be expanded to a larger set of option
classes or constricted to a smaller set. This question presents empirical challenges because the
option classes added to the Pilot are generally the most liquid, thus making it difficult to
extrapolate the benefits of the Pilot to less liquid option classes. We address this by examining
market quality for Penny Pilot option classes using a more recent period of February 2016. The
examination of a recent period allows us to study Penny Pilot option classes that may have been
more liquid when they were originally added to the Pilot but with the passage of time became
less liquid. The analysis compares spreads between Pilot options and a control sample of (nonPilot) options, matched on option volume, underlying market capitalization, and underlying
price. Results are reported by option volume quartiles to examine whether the benefits of
inclusion in the Pilot taper off at a particular threshold (Table 23). The results indicate evidence
of significant benefits of inclusion in the Pilot for the top two quartiles, corresponding to the
option classes with trading volume in the top 5% of the universe of all listed option classes. For
the bottom two quartiles of Pilot options, most of the results are not statistically significant,
suggesting that the benefits of the Pilot decline as option liquidity declines.

I.

Background: Option Penny Pilot Program
On Friday, January 26, 2007, the options exchanges commenced the Pilot program to

quote and trade options on 13 stocks and ETFs in one-cent increments. The Pilot specified that
options trading at less than $3.00 would have trading increments of one cent, while those trading

4

at $3.00 or more would have trading increments of five cents, with the exception of options on
the QQQQ which would trade at one cent increments, regardless of price level. The change
represents a reduction relative to options not in the Pilot, which have corresponding minimum
price increments of five cents for options trading below $3.00 and ten cents for options trading
above $3.00.
As summarized in Table 1, the Pilot was subsequently expanded to include additional
option classes. Most notably, the Pilot was expanded by an additional 22 option classes on
September 28, 2007 and 28 option classes on March 28, 2008. The Pilot was subsequently
expanded to include the next 300 most actively traded, multiply-listed options classes that were
not yet included in the Pilot, excluding options with high premiums. These option classes were
added in groups of 75 on each of November 2, 2009, February 1, 2010, May 3, 2010, and August
2, 2010. Further, SPX and IWM began trading in one-cent increments regardless of the price
level on February 1, 2010. Since 2011, additions have occurred at the beginning of January and
July each year, when a handful of options (less than 10) have been added to the Pilot to replace
options that no longer exist.2 This analysis encompasses the addition to the Pilot of options on
common equity and ETFs, commencing on January 26, 2007 and concluding on January 5, 2016.

II.

Data and Sample
Options Price Reporting Authority (OPRA) data were obtained from CBOE LiveVol,

which contains options trades, along with contemporaneous quotes from each exchange, as well
as the National Best Bid and Offer (NBBO). For each of the event dates listed in Table 1

2

See https://www.ise.com/options/regulatory-and-fees/options-penny-pilot/.
5

beginning in January 2007 and ending with the addition in January 2016, OPRA data were
obtained for the full calendar month prior to the event date (“pre-event month”) and for the full
calendar month subsequent to the event date (“post-event month”). For example, for the event
date on January 26, 2007, data were obtained for the calendar months of December 2006 and
February 2007.
The OPRA data were supplemented with data from the Center for Research in Security
Prices (CRSP) and OptionMetrics. CRSP data were used to obtain characteristics of the
underlying equity instrument, including market capitalization, average daily trading volume, and
prices. Daily OptionMetrics data were used to obtain additional characteristics of the traded
option series and to provide a mapping between the OPRA and CRSP data.
The analysis is focused on options on common stock and ETFs, with results reported
separately for common stock and ETFs.3 Option classes for which the underlying stock or ETF
traded below $1 or above $1,000 on any day during the pre-event month or the post-event month
of any addition date are excluded, as are option series with non-standard settlements. Outlier
spreads (effective or quoted) which are greater than $5 when the option price is less than $100,
or are greater than $10, are excluded from the analysis. The sample for option classes on
common stock incorporates data on 3,833 option classes and 1,331,185 class-day observations.
The sample for option classes on ETFs incorporates data on 693 option classes and 194,694
class-day observations.

3
The analyses reported in the body of this memo are based on a database of regular option trades (trades involving
only one leg). An analysis of complex trades shows similar results and is reported in the Appendix.

6

III.

Characteristics of Options Added to the Pilot
Table 2 contains summary statistics for option class volume, underlying volume, and

underlying market capitalization for option classes not in the Pilot, classes being added to the
Pilot, and classes already in the Pilot, computed during the pre-event month. Switching option
classes generally have a higher average daily option volume, higher average daily underlying
stock volume, and higher underlying market capitalization vis-à-vis option classes outside the
Pilot. This is not surprising and simply reflects the fact that more actively traded options on
more actively traded and larger stocks tend to be selected for inclusion in the Pilot. Note that the
volume and market cap metrics for switching options decreased substantially between 2007 and
2010, indicating that option classes with higher volume and market cap were added to the Pilot
prior to option classes with lower volume and market cap.
Since the large number of illiquid options may unduly influence the average for volume
and underlying market capitalization for options outside the Pilot, it is worth examining the
distribution of these characteristics across all option classes. Figure 1 shows a scatterplot of
option classes on common stock based on average daily option volume and underlying market
capitalization, while Figure 2 plots option classes on common stock based on average daily
underlying volume and underlying market capitalization. Figures 3 and 4 show analogous plots
for option classes on ETFs. All figures plot the data as of February 2016. The distributions
confirm that options in the Pilot have higher trading volume and larger underlying market
capitalizations vis-à-vis the overall population of traded options.

7

IV.

Control Sample
The primary goal of this research is to assess the degree to which including an option

class in the Pilot resulted in narrower quoted and effective spreads. Quoted and effective spreads
are frequently used as measures of trading costs and, more generally, to assess market quality.
Even though the analysis focuses on relatively short windows of one month before and one
month after each addition date, it is possible that other market-wide factors influencing option
spreads might have changed systematically between the pre-event and post-event months. The
difference-in-differences methodology recognizes this possibility and controls for any such
market-wide factors by comparing changes in market quality for the added option classes with
contemporaneous changes in a control sample of option classes that were not added.
Control samples are constructed by matching switching options with non-switching
options on the basis of option class volume and underlying market capitalization. Specifically,
each switching option was matched with a control option by rank ordering the entire universe of
traded options on option class volume and underlying market capitalization in the pre-event
month, and then minimizing the difference in ranks between the switching option and the control
option. Matching was completed without replacement, that is, each control option class is
matched with exactly one switching option class for each event date. The results are similar
across two different sets of matched controls: an “unconstrained” set, where the matched option
is any non-switching option regardless of whether it is in the Pilot, and a “constrained” set,
where the control option must be outside the Pilot. In later years, when most of the highest
option volume options are in the Pilot, the unconstrained sample is likely to provide a closer
match for the volume of the switching option. Table 3 contains summary statistics for the

8

control samples for option classes on common stock during the pre-event month. Table 4
contains the same summary statistics for option classes on ETFs.

V.

Impact of the Pilot on Quoted and Effective Spreads
Figures 5–8 graphically illustrate the impact on spreads for the switching options after

being added to the Pilot vis-à-vis the control sample. Figure 5 depicts the average dollar
effective spreads during the pre-event month and the post-event month across the different
addition dates. As can be seen in Figure 5, dollar effective spreads for switching options are
substantially lower in the post-event month as compared to the pre-event month. No
corresponding decline in effective spreads occurs for the control sample. A similar pattern is
observed for relative effective spreads (Figure 6), dollar quoted spreads (Figure 7), and relative
quoted spreads (Figure 8). Figures 9–12 show a similar pattern for option classes on ETFs.
These figures suggest that inclusion in the Pilot is associated with substantially lower quoted and
effective spreads.4
Tables 5–12 present changes in effective and quoted spreads for options that are
switching into the Pilot,5 as compared to a control group of non-switching options. Spreads are
volume-weighted across different trades in an option series and then equally weighted across
option series, in order to obtain spreads for the option-class day. Those spreads are then equally
weighted across different days in the pre-event month and the post-event month, respectively, in

4

The graphs shown in Figures 5–8 are based on event-time data aggregated across all event dates. Similar graphs
could be made for any individual event date. For example, a graph showing the evolution of spreads surrounding
August 2, 2010 is provided in the Appendix.
5
The addition dates in January 2010 and July 2010 are the pre-event months for the additions in February 2010 and
August 2010, respectively and, hence, are excluded as addition dates from the analysis to ensure that event windows
do not overlap.
9

order to obtain option-class month observations. A similar methodology is adopted for
computing spreads for the control sample, and the results of a difference-in-differences
specification are reported. P-values are computed using a paired t-test and the Wilcoxon SignedRank test.
As shown in the first panel in Table 5, average dollar effective spreads declined from
10.5 cents in the pre-event month to 6.8 cents in the post-event month for the switching options
in the overall sample, a decrease of 3.7 cents, while effective spreads in the control sample
decreased by 0.2 cents. Relative to the control sample, effective spreads declined by 3.5 cents,
as reported in the column labeled “diff-in-diff.” This decline is statistically significant (at the 1%
level). Table 5 also reports results for the different subperiods. As indicated in the table,
inclusion in the Pilot is associated with a decrease in effective spreads of 3.3 cents for classes
added between 2007 and 2009, 3.8 cents for classes added between 2010 and 2011, and 1.4 cents
for classes added between 2012 and 2015. The second panel of Table 5 reports analogous results
based on percentage effective spreads.
Similarly, as shown in the third panel of Table 5, average dollar quoted spreads declined
from 13.9 cents in the pre-event month to 8.7 cents in the post-event month for the switching
options in the overall sample, while quoted spreads for the control sample decreased from 12.4 to
12.2 cents. Based on the difference-in-differences, inclusion in the Pilot is associated with a
decline in quoted spreads of 5.1 cents, which is statistically significant at the 1% level.
One potential explanation for the smaller decrease in spreads for later additions to the
Pilot is that the benefits of the Pilot are most pronounced for options on larger stocks or for
option classes with the highest trading volume, and to the extent that recent additions to the Pilot

10

tend to be smaller stocks with lower-volume options, there would be smaller declines in spreads
in recent years.
To examine this, Table 6 decomposes the sample into categories based on the underlying
market capitalization, using breakpoints calculated from NYSE stocks. Because most options
being added are in the largest market capitalization quartile, they are decomposed into more
granular categories. The difference-in-differences spreads are negative and statistically
significant for all categories, with the Wilcoxon Signed-Rank test significant at the 1% level.
Average dollar effective spreads declined by 3.5 cents for the largest quartile, by 3.6 cents for the
third quartile, and by 2.9 cents for options below the 50th percentile, vis-à-vis the changes in the
control group. Thus, the spread declines for Pilot stocks are consistent across all market cap
categories. In addition, all four spread measures show similar results.
Table 7 decomposes the sample based on the percentile of the option volume in the preevent month. Because almost the entire population of the switching options is in the top 10% by
volume, they are decomposed into more granular categories. The difference-in-differences
spreads are negative and statistically significant for all categories, with the Wilcoxon SignedRank test significant at the 1% level. Relative effective spreads declined by 4.4% for the top two
percentiles, by 6% for the 95th to 97th percentile, by 5.5% for the 90th to 94th percentile, and by
7.2% for options below the 90th percentile, vis-à-vis changes in the control groups. The spread
declines for Pilot option classes are consistent across all volume categories for all four spread
measures.
Table 8 decomposes the sample based on the quoted price for an option. The differencein-differences spreads are negative and statistically significant for all categories, with the
Wilcoxon Signed-Rank test significant at the 1% level. Average dollar effective spreads
11

declined by 2.7 cents for options priced below $1.00, by 2.9 cents for options priced between
$1.00 and $3.00, by 4.2 cents for options priced between $3.00 and $5.00, and by 4.6 cents for
options priced over $5.00, vis-à-vis the changes in the control group. The spread declines for
Pilot option classes are consistent across all price categories for all four spread measures.
Table 9 decomposes the sample based on the time to expiration for an option. The
difference-in-differences spreads are negative and statistically significant for all categories, with
the Wilcoxon Signed-Rank test significant at the 1% level. Average dollar effective spreads
declined by 3.4 cents for options expiring within a week, by 3 cents for options expiring between
one and four weeks, and by 3.6 cents for options expiring in more than four weeks, vis-à-vis the
changes in the control group. The spread declines for Pilot option classes are consistent across
all expiration categories for all four spread measures.
Tables 10–12 show results for option classes on ETFs decomposed by addition year,
underlying market capitalization (as measured by price multiplied by shares outstanding), and
option volume. Overall, average dollar effective spreads declined by 5 cents and average dollar
quoted spreads declined by 6.8 cents. When decomposed by the market capitalization of the
underlying ETF or by option trading volume, all difference-in-differences spreads are negative
and statistically significant at the 1% level for the Wilcoxon Signed-Rank test.
The difference-in-differences analysis described above has focused on examining the
impact of the Pilot on effective spreads and quoted spreads. The same technique can also be
applied to examine other market characteristics. For example, analysis showing the impact on
average daily trading volume, average trade size, and quoted depth at the NBBO is presented in
the Appendix.

12

VI.

Regression Analysis
The difference-in-differences analysis reported in the previous section used a control-

sample methodology to control for any market-wide difference in factors that might have
affected spreads between the pre-event and post-event months. This section presents further
results based on a multivariate regression methodology that further controls for changes in other
factors that might affect spreads, including option volume, stock volume, and equity volatility.
A.

Baseline Regression Specification (Contains All Options)

The baseline multivariate regression approach is estimated at the class-day level for
periods covering a calendar month prior to, and a calendar month subsequent to, each date of
addition to the Pilot and contains all traded option classes:

,

,

where

,

particular day;

,

,

,

,

is the binary variable of interest, taking a value of 1 in the post-switch
,

is the log of option class volume;

is the log of underlying stock volume on the
,

is the underlying stock volatility

calculated as the difference between the high and low prices of the day divided by the closing
price;

,

is a measure of quoted or effective spreads for a particular option class on a

period for options switching to the Pilot;
day;

,

is an option class fixed effect; and
The variable of interest

,

is a date fixed effect.

is the interaction term between indicator variables for the

switching options and the post-switch period. The specification does not include individual

13

(main effect) indicator variables for switching options and the post-switch period because these
are subsumed by the option class and date fixed effects. The model is estimated on observations
at the class/day level, and the dependent variable is constructed by aggregating spread measures
across the option series within the same class. The spreads are first volume-weighted across
trades within each option series-day and then equally weighted across option series to obtain
option class-day spreads. Hence, this specification incorporates all option series within the
option classes with positive trading volume. The model is estimated on a sample including all
option class/day measures for the calendar month prior to, and the calendar month after, each
date of addition to the Pilot for all options. Standard errors are clustered on option class and
date.
B.

Matched Sample Regression Specification (Contains Only Matched Sample)

We also estimate an alternative specification, which has three key differences with the
baseline specification. First, the alternate specification contains only the matched sample for
each event, where an event constitutes a pre-event and post-event month for an addition.
Second, the variable of interest is a switching indicator (which takes on a value of 1) only in the
post-event month for the switching options. This indicator is zero for the control options,
regardless of whether they are in the Pilot or not. Third, the option class fixed effect is replaced
with an option class event fixed effect, since the same control option may be outside the Pilot for
a particular event and may be in the Pilot for another event.

14

C.

Findings

Table 13 reports results for effective spreads using the baseline specification estimated
over the pre-event month and post-event month for the full sample, as well as for the different
time periods. The indicator variable of interest is negative and statistically significant (at the 1%
level) for effective spreads (for the full sample and for all time periods, except for the most
recent additions in 2012–2015), showing a decline in trading costs for options being added to the
Pilot. Dollar effective spreads declined by an average of 8.8 cents after addition to the Pilot for
the full sample. Comparing the different subperiods separately, the maximum decline in spreads
is for the additions in the 2010–2011 period (8 cents). The indicator is not statistically
significant for the most recent additions from 2012–2015, with a coefficient close to zero.
Similarly, Table 14 reports results for quoted spreads using the baseline multivariate
regression framework. Dollar quoted spreads declined by 16.1 cents for the entire sample, which
is statistically significant. Comparing the subperiods individually, the decline is strongest in the
2010–2011 subperiod (12.2 cents), and is not statistically significant for additions made in the
2012–2015 subperiod.
Table 15 reports regression results for effective spreads using the matched sample
approach, for the complete time period as well as for different subperiods. Dollar effective
spreads declined by 3.6 cents for the full sample, which is statistically significant at the 1% level.
The coefficient of interest (i.e., switching indicator) is statistically significant and negative across
all specifications, including the 2012–2015 subperiod. Similar results are reported in Table 16
for quoted spreads, with dollar quoted spreads declining by 5.2 cents for the full sample, which is
statistically significant at the 1% level.

15

Table 17 reports regression results for effective spreads using the matched sample
approach, decomposed into different market capitalization categories. The coefficient of interest
(i.e., switching indicator) is statistically significant and negative across all categories. Similar
results are reported in Table 18 for quoted spreads.
Table 19 reports regression results for effective spreads using the matched sample
approach, decomposed into different categories based on option volume. The coefficient of
interest (i.e., switching indicator) is statistically significant and negative across all categories.
Similar results are reported in Table 20 for quoted spreads.
Table 21 reports regression results for option classes on ETFs using the full sample and
matched sample approach. Similar to the common stock sample, the results show that switching
to the Penny Pilot has a significant (at the 5% level) negative effect on quoted spreads. For
effective spreads, we find similar negative effects (significant at the 1% level), with the
exception of the effective dollar specification for the full ETF sample.

VII.

Impact of Pilot on the Least Liquid Option Classes
Based on the results reported above, we observe a decline in spreads for option classes in

the Pilot vis-à-vis the control options, which is robust across different spread measures, as well
as different partitions based on market capitalization, option volume, etc. This does not
necessarily imply that all option classes would benefit from inclusion in the Pilot because, as
noted above, the Pilot option classes are not representative of the overall population of option
classes, but tend to be the most liquid. Many option classes currently not in the Pilot have lower

16

trading volume than those currently in the Pilot. It is not clear the extent to which similar
benefits might be realized should penny quoting be expanded to include such option classes.
With the passage of time, some Pilot option classes (which may have had high trading
volume at the time of inclusion) may have become less active, to the point that they would no
longer be selected for the Pilot if the decision were made today. Among the Pilot option classes,
those with the lowest current volume and market capitalization are the most similar to the
options outside the Pilot. Analysis of these options could provide insight into the benefits that
might be experienced by less liquid options upon inclusion.
Table 22 provides characteristics of Pilot option classes as well as matched control
options as of February 2016. Control samples were constructed by matching Pilot options with
non-Pilot options on the basis of option class volume, underlying market capitalization, and
underlying price.6 To ensure robustness, control samples were designed so that the matching
was completed with replacement (i.e., an out-of-Pilot option class can match with any number of
in-Pilot option classes), as well as without replacement (i.e., an out-of-Pilot option class can
match with only one in-Pilot option class). Even with the passage of time, Pilot options are more
liquid than the overall option universe, with the top quartile of Pilot options by option volume in
the top three percentiles of the overall universe. Moreover, even the smallest Pilot option classes
have option volumes greater than the volume of the 40th percentile in the overall option class

6

Each Pilot option class was matched with a control option outside the Pilot by rank ordering the entire universe of
traded options on option class volume, underlying market capitalization, and underlying price as of February 2016,
and then minimizing the difference in ranks between the Pilot option and the control option.

17

universe; hence, the identification of the impact of inclusion of option classes below the 40th
percentile is not possible using this sample.
Table 23 analyzes the difference in spreads between the Pilot option classes and the
control options as of February 2016.7 Results are reported by option volume quartiles to analyze
if there is a discontinuity at which point the benefits of being in the Pilot taper off. Analyzing
the results across the different quartiles, the difference in spreads is negative and mostly
statistically significant for the top two quartiles. Hence, consistent with the difference-indifferences analysis, the Pilot appears to be beneficial for the top two quartiles of Pilot options.
The top two quartiles are in the 95th percentile of the overall option universe. Thus, these results
show that the penny tick size is associated with the benefit of narrower spreads for option classes
in the top 5% of option volume.8 Analyzing the difference in spreads for the bottom two
quartiles, the test statistics are negative, but most are not statistically significant, suggesting that
the benefits of the Pilot decline as option liquidity declines. However, the absence of evidence
that market quality has deteriorated suggests that inclusion of lower-volume option classes may
not be not harmful.

VIII. Conclusion
This research has examined data covering the entire history of the Option Penny Pilot
from its inception and has analyzed how inclusion in the Pilot has impacted effective spreads and

7

Note that this is a difference in spreads specification, rather than the difference-in-differences specification used
previously.
8
We note two limitations of our analysis–one, the control sample of options have significantly lower volume than
the Penny Pilot options since most of the high volume options are in the Pilot, and two, that our analysis is limited to
liquidity metrics that can be calculated using available data. For example, we are unable to comment on the impact
of the Pilot on overall trading costs faced by institutions with large orders.
18

quoted spreads for option classes added to the Pilot through January 2016. The results indicate
that inclusion in the Pilot is associated with a statistically significant decline in effective spreads
and quoted spreads. This result is found to hold across all subperiods, but the magnitude of the
effect appears to be smaller for additions after 2012. Results are presented for options with
varying levels of trading volume and underlying market capitalization and appear to be robust
across categories. The results presented above focus on options on common stock, although
similar results are found for ETF options as discussed above. Similar results are found for
complex trades and are presented in the Appendix. The impact of inclusion in the Pilot on other
dimensions of market quality, such as quoted depth, are also presented in the Appendix.
This research further seeks to provide evidence to assist the staff in evaluating whether
the program should be expanded (or contracted) by examining the spreads of Pilot option classes
vis-à-vis matched controls as of February 2016. The results show a benefit of narrower spreads
for option classes in the top 5% of the universe. However, there is less less evidence of benefit
for lower-volume option classes. We find no evidence of a harmful increase in spreads for any
category of option classes.
In summary, the evidence suggests that the existing Pilot program has resulted in
improvements in market quality (as measured by quoted and effective spreads) for the Pilot
option classes. This research does not provide any clear evidence that expanding the Pilot to
include lower-volume stocks would result in similar benefits.
It is worth noting that this research does not account for the different fee structure option
exchanges have for classes within and outside the Pilot. It is common among exchanges to have
separate fee structures for Penny Pilot options. The research summarized herein does not
attempt to disentangle whether the observed improvements in market quality can be attributed to
19

the Pilot alone, or if they may also be influenced by the differential fee structure. The average
declines in execution costs for the most liquid option classes appear to be substantially higher
than the potential impact of any fee adjustments.

20

Figure 1
Average Daily Option Class Volume vs. Market Capitalization
February 2016
Log Average
10

Option Class Volume
6

5

4

3

2
Not in Pilot
In Pilot

1

0

-1

-2
7

7.5

8

Source: LiveVol; OptionMetrics; CRSP.

8.5

9

9.5

10

10.5

11

11.5

Log10 Market Capitalization

Note: Includes all option classes on common stock for which LiveVol has data in February 2016. Share codes 10 and 11 are used to identify common stock in
the CRSP data.

12

Figure 2
Average Daily Underlying Volume vs. Market Capitalization
February 2016
Log Average
10

Underlying Volume
8.5
8
7.5
7
6.5
6
5.5
Not in Pilot

5

In Pilot
4.5
4
3.5
3
7

7.5

8

Source: LiveVol; OptionMetrics; CRSP.

8.5

9

9.5

10

10.5

11

11.5

Log10 Market Capitalization

Note: Includes all option classes on common stock for which LiveVol has data in February 2016. Share codes 10 and 11 are used to identify common stock in
the CRSP data.

12

Figure 3
Average Daily Option Class Volume vs. Market Capitalization
Option Classes on ETFs
Log Average
Option Class Volume
February 2016
10

8

7

6

5

4
Not in Pilot
In Pilot

3

2

1

0
6

7

Source: LiveVol; OptionMetrics; CRSP.

8

9

10

11

Log10 Market Capitalization

Note: Includes all option classes on ETFs for which LiveVol has data in February 2016. Share code 73 is used to identify ETFs in the CRSP data.

12

Figure 4
Average Daily Underlying Volume vs. Market Capitalization
Option Classes on ETFs
Log Average
Underlying Volume
February 2016
10

10

9

8

7

6
Not in Pilot
In Pilot
5

4

3
6

7

Source: LiveVol; OptionMetrics; CRSP.

8

9

10

11

Log10 Market Capitalization

Note: Includes all option classes on ETFs for which LiveVol has data in February 2016. Share code 73 is used to identify ETFs in the CRSP data.

12

Figure 5
Impact of Addition to the Penny Pilot on Effective Spreads ($)
Effective Spread
$0.14
Penny Pilot
Addition

$0.12

$0.10

$0.08

$0.06
Switching
Control
$0.04

$0.02

$0.00
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 235 option classes on common stock that were added to the Penny Pilot between January 26, 2007 and July 6, 2015 for which
LiveVol has data. 12 option classes were removed because the switching option class or the control option class was missing data on an option
class-day in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot
based on underlying market capitalization and option volume. Effective spreads for the switching and control samples are averaged across each
trading day.

Figure 6
Impact of Addition to the Penny Pilot on Effective Spreads (%)
Effective Spread
20%
Penny Pilot
Addition
16%

12%

8%

Switching
Control

4%

0%
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 235 option classes on common stock that were added to the Penny Pilot between January 26, 2007 and July 6, 2015 for which
LiveVol has data. 12 option classes were removed because the switching option class or the control option class was missing data on an option
class-day in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot
based on underlying market capitalization and option volume. Effective spreads for the switching and control samples are averaged across each
trading day.

Figure 7
Impact of Addition to the Penny Pilot on Quoted Spreads ($)
Quoted Spread
$0.18
Penny Pilot
Addition
$0.15

$0.12

$0.09

Switching
$0.06

Control

$0.03

$0.00
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 235 option classes on common stock that were added to the Penny Pilot between January 26, 2007 and July 6, 2015 for which
LiveVol has data. 12 option classes were removed because the switching option class or the control option class was missing data on an option
class-day in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot
based on underlying market capitalization and option volume. Quoted spreads for the switching and control samples are averaged across each
trading day.

Figure 8
Impact of Addition to the Penny Pilot on Quoted Spreads (%)
Quoted Spread
21%
Penny Pilot
Addition

18%

15%

12%

9%
Switching
Control
6%

3%

0%
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 235 option classes on common stock that were added to the Penny Pilot between January 26, 2007 and July 6, 2015 for which
LiveVol has data. 12 option classes were removed because the switching option class or the control option class was missing data on an option
class-day in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot
based on underlying market capitalization and option volume. Quoted spreads for the switching and control samples are averaged across each
trading day.

Figure 9
Impact of Addition to the Penny Pilot on Effective Spreads ($)
Option Classes on ETFs
Effective Spread
$0.16
Penny Pilot
Addition

$0.14

$0.12

$0.10

$0.08

$0.06

Switching
Control

$0.04

$0.02

$0.00
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 53 option classes on ETFs that were added to the Penny Pilot between January 26, 2007 and January 5, 2016 for which LiveVol
has data. Two option classes were removed because the switching option class or the control option class was missing data on an option class-day
in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot based on
underlying market capitalization and option volume. Effective spreads for the switching and control samples are averaged across each trading day.

Figure 10
Impact of Addition to the Penny Pilot on Effective Spreads (%)
Option Classes on ETFs
Effective Spread
20%
Penny Pilot
Addition
16%

12%

8%

Switching
Control

4%

0%
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 53 option classes on ETFs that were added to the Penny Pilot between January 26, 2007 and January 5, 2016 for which LiveVol
has data. Two option classes were removed because the switching option class or the control option class was missing data on an option class-day
in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot based on
underlying market capitalization and option volume. Effective spreads for the switching and control samples are averaged across each trading day.

Figure 11
Impact of Addition to the Penny Pilot on Quoted Spreads ($)
Option Classes on ETFs
Quoted Spread
$0.24
Penny Pilot
Addition

$0.21

$0.18

$0.15

$0.12

$0.09

Switching
Control

$0.06

$0.03

$0.00
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 53 option classes on ETFs that were added to the Penny Pilot between January 26, 2007 and January 5, 2016 for which LiveVol
has data. Two option classes were removed because the switching option class or the control option class was missing data on an option class-day
in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot based on
underlying market capitalization and option volume. Quoted spreads for the switching and control samples are averaged across each trading day.

Figure 12
Impact of Addition to the Penny Pilot on Quoted Spreads (%)
Option Classes on ETFs
Quoted Spread
24%
Penny Pilot
Addition

21%

18%

15%

12%

9%

Switching
Control

6%

3%

0%
Pre-Addition Month

Post-Addition Month

Source: LiveVol; OptionMetrics, CRSP.
Note: Includes 53 option classes on ETFs that were added to the Penny Pilot between January 26, 2007 and January 5, 2016 for which LiveVol
has data. Two option classes were removed because the switching option class or the control option class was missing data on an option class-day
in the pre-addition or post-addition month. Each switching option class is matched with a non-switching option class outside the Pilot based on
underlying market capitalization and option volume. Quoted spreads for the switching and control samples are averaged across each trading day.

Table 1
Option Classes Added to Penny Pilot
Since Inception
Date

New Option Classes Added

(%)

1/26/2007
9/28/2007
3/28/2008
11/2/2009
1/5/2010
2/1/2010
5/3/2010
7/6/2010
8/2/2010
1/4/2011
7/6/2011
1/4/2012
7/3/2012
1/3/2013
7/3/2013
1/3/2014
7/3/2014
1/5/2015
7/6/2015
1/5/2016
7/6/2016
Total

13
22
23
75
4
75
75
3
75
2
4
3
2
9
2
7
4
2
6
2
7
415

3.19%
5.39%
5.64%
18.38%
0.98%
18.38%
18.38%
0.74%
18.38%
0.49%
0.98%
0.74%
0.49%
2.21%
0.49%
1.72%
0.98%
0.49%
1.47%
0.49%
1.69%
100.00%

Source: ISE Penny Pilot Addition Dates.

Table 2
Liquidity Metrics for Penny Pilot Addition Dates
Option Classes on Common Stock
Daily Volume of Option Class
(Contracts)

Number of Option Classes
Month

Not in Pilot

Switching

Dec-06

2,030

9

Aug-07

2,011

Feb-08

In Pilot

Not in Pilot

Switching

0

1,636

32,572

15

9

1,843

2,001

20

25

Oct-09

1,890

41

Dec-09

1,950

Jan-10

Daily Volume of Underlying Stock
(Thousands)

In Pilot

Not in Pilot

Switching

–

1,390

26,137

51,330

29,632

1,983

1,481

30,794

48,095

43

1,177

22,411

3

85

755

1,823

50

87

Apr-10

1,839

49

Jul-10

1,767

Dec-10

In Pilot

Market Cap of Underlying Stock
($Millions)
Not in Pilot

Switching

In Pilot

–

6,920

102,942

–

22,195

35,759

6,341

94,746

106,900

1,684

21,527

30,027

4,951

88,186

80,364

65,407

1,596

17,257

39,943

3,144

43,505

68,857

10,000

33,977

1,205

11,925

23,211

3,365

23,018

60,045

866

9,080

44,974

1,260

8,250

30,600

2,719

22,664

57,192

140

652

7,528

35,862

1,281

6,237

23,736

2,881

10,254

49,019

46

180

457

3,807

20,062

1,042

5,379

15,530

2,361

13,425

36,905

1,790

1

224

477

4,869

18,171

838

8,813

10,840

2,763

209

36,900

Jun-11

1,824

3

225

502

15,136

15,679

960

7,886

10,004

2,902

20,199

38,065

Dec-11

1,888

1

233

381

11,989

14,393

878

4,695

9,122

2,637

5,077

35,131

Jun-12

1,899

2

233

502

15,814

15,015

976

18,695

9,575

2,781

9,861

38,136

Dec-12

1,885

5

225

378

40,885

16,414

764

16,823

8,422

2,892

12,502

40,393

Jun-13

1,989

1

233

486

64,427

15,264

865

9,097

9,000

3,276

13,037

43,755

Dec-13

2,047

3

226

567

16,306

16,847

773

5,198

7,072

3,809

6,630

50,908

Jun-14

2,144

1

227

505

123,725

15,879

803

31,263

6,311

3,951

24,170

52,975

Dec-14

2,187

1

229

437

8,256

16,487

821

5,921

7,014

4,003

26,587

55,218

Jun-15

2,206

2

227

391

18,684

13,805

830

7,078

6,817

4,035

6,374

55,257

Source: CRSP; OptionMetrics; LiveVol.
Note: Liquidity metrics are shown for the month prior to each addition date. The liquidity metrics includes all option classes on common stock for which LiveVol has data. Share codes 10 and 11 are used to
identify common stock in the CRSP data. The sample excludes option classes for which the underlying stock traded below $1 or above $1,000 on any day on which an average spread is calculated during the
December 2006 through February 2016 period. Data for the July 2010 and January 2016 additions is not shown above because none of the option classes that switched on those dates are in the sample of option
classes on common stock.

Table 3
Liquidity Metrics for Penny Pilot Addition Dates
Matched Pairs Sample
Daily Volume of Option Class (Contracts)

Daily Volume of Underlying Stock (Thousands)

Market Cap of Underlying Stock ($Millions)

Month

Number of Option
Classes

Switching

Unconstrained

Constrained

Switching

Unconstrained

Constrained

Switching

Unconstrained

Constrained

Dec-06

9

32,572

27,896

27,896

26,137

18,426

18,426

102,942

76,960

76,960

Aug-07

15

51,330

36,314

36,353

22,195

27,659

18,002

94,746

101,936

85,218

Feb-08

20

30,794

44,490

22,451

21,527

31,756

16,848

88,186

85,362

65,385

Oct-09

41

22,411

23,793

11,851

17,257

17,117

9,666

43,505

37,261

25,440

Jan-10

50

9,080

9,246

6,915

8,250

7,668

5,598

22,664

18,788

14,558

Apr-10

46

7,990

9,654

5,705

6,271

7,387

7,463

10,010

10,163

9,934

Jul-10

46

3,807

3,853

3,241

5,379

5,516

3,930

13,425

13,119

11,582

Dec-10

1

4,869

1,793

1,793

8,813

1,993

1,993

209

259

259

Jun-11

3

15,136

14,755

8,719

7,886

12,246

2,248

20,199

20,167

11,981

Dec-11

1

11,989

15,117

6,524

4,695

11,795

3,703

5,077

5,099

4,783

Jun-12

2

15,814

11,767

11,767

18,695

6,119

6,119

9,861

9,777

9,777

Dec-12

5

40,885

37,142

8,880

16,823

17,370

4,000

12,502

13,173

10,139

Jun-13

1

64,427

37,025

9,730

9,097

3,079

2,784

13,037

12,438

9,251

Dec-13

3

16,306

15,206

9,946

5,198

4,131

4,420

6,630

6,930

7,677

Jun-14

1

123,725

59,340

26,590

31,263

2,402

9,795

24,170

26,476

33,033

Dec-14

1

8,256

8,265

7,583

5,921

8,410

8,833

26,587

29,393

28,724

Jun-15

2

18,684

25,054

8,856

7,078

13,617

23,484

6,374

6,202

6,616

Source: CRSP; OptionMetrics; LiveVol.
Note: Liquidity metrics are shown for the month prior to each addition date. The matched pairs sample is constructed from the universe of option classes on common stock for which LiveVol has data. Each
switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. For “constrained” matching, the non-switching class must be outside of the Pilot.
Data for the January 2010 and July 2010 additions are not shown above because the post-month for these two addition dates overlapped with the February 1, 2010 and August 2, 2010 additions respectively. Data
for the January 2016 additions is not shown above because none of the option classes that switched on that date are in the sample of option classes on common stock.

Table 4
Liquidity Metrics for Penny Pilot Addition Dates
Matched Pairs Sample: Option Classes on ETFs
Daily Volume of Option Class (Contracts)

Daily Volume of Underlying Stock (Thousands)

Market Cap of Underlying Stock ($Millions)

Month

Number of Option
Classes

Switching

Unconstrained

Constrained

Switching

Unconstrained

Constrained

Switching

Unconstrained

Constrained

Dec-06

3

140,034

77,111

63,380

50,208

22,732

21,345

10,224

23,872

24,586

Aug-07

4

230,200

208,085

208,085

101,194

49,351

49,351

22,471

9,615

9,615

Feb-08

1

43,739

584,226

584,226

22,226

151,137

151,137

25,362

16,420

16,420

Oct-09

19

27,803

90,613

6,741

24,030

32,762

8,190

6,404

8,236

2,567

Jan-10

6

10,953

9,705

8,186

17,443

9,969

5,050

1,811

2,324

2,473

Apr-10

7

5,283

6,152

2,920

7,414

7,624

3,770

2,368

2,462

2,083

Jul-10

6

1,727

2,390

1,696

3,552

3,273

2,817

1,190

1,123

1,047

Dec-10

0

–

–

–

–

–

–

–

–

–

Jun-11

0

–

–

–

–

–

–

–

–

–

Dec-11

0

–

–

–

–

–

–

–

–

–

Jun-12

0

–

–

–

–

–

–

–

–

–

Dec-12

1

15,267

6,892

6,685

7,671

3,712

1,399

726

763

767

Jun-13

0

–

–

–

–

–

–

–

–

–

Dec-13

2

16,713

10,133

7,237

7,116

3,259

2,045

6,446

6,666

7,653

Jun-14

0

–

–

–

–

–

–

–

–

–

Dec-14

0

–

–

–

–

–

–

–

–

–

Jun-15

3

10,538

12,301

11,827

7,536

5,672

3,882

5,606

5,249

7,690

Dec-15

1

8,011

12,763

4,426

1,600

834

3,386

400

340

464

Source: CRSP; OptionMetrics; LiveVol.
Note: Liquidity metrics are shown for the month prior to each addition date. The matched pairs sample is constructed from the universe of ETFs for which LiveVol has data. Each switching option class is matched
with a non-switching option class based on underlying market capitalization and option volume. For “constrained” matching, the non-switching class must be outside of the Pilot. Data for the January 2010 and July
2010 additions are not shown above because the post-month for these two addition dates overlapped with the February 1, 2010 and August 2, 2010 additions respectively.

Table 5
Univariate Statistics Reported by Penny Pilot Addition Date Periods
Unconstrained Matching
Switching
Addition Dates

N

Average Daily Average Daily
Trade Count
Volume

Pre

Post

Change

Non-Switching
P-Value

Pre

Post

Change

P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Effective Spread ($)
All

247

912

16,940

0.105

0.068

-0.037

0.000

0.096

0.094

-0.002

0.195

-0.035

0.000

0.000

2007 – 2009
2010 – 2011

85
146

1,363
443

30,563
7,181

0.109
0.098

0.066
0.062

-0.042
-0.036

0.000
0.000

0.101
0.090

0.093
0.093

-0.009
0.002

0.000
0.213

-0.033
-0.038

0.000
0.000

0.000
0.000

2012 – 2015

16

2,795

33,618

0.144

0.129

-0.015

0.011

0.122

0.120

-0.001

0.779

-0.014

0.019

0.009

Effective Spread (%)
All

247

912

16,940

0.138

0.090

-0.048

0.000

0.113

0.122

0.009

0.004

-0.058

0.000

0.000

2007 – 2009
2010 – 2011
2012 – 2015

85
146
16

1,363
443
2,795

30,563
7,181
33,618

0.140
0.132
0.179

0.085
0.087
0.138

-0.055
-0.046
-0.041

0.000
0.000
0.000

0.113
0.111
0.131

0.116
0.126
0.122

0.004
0.015
-0.009

0.252
0.004
0.223

-0.058
-0.060
-0.032

0.000
0.000
0.003

0.000
0.000
0.006

0.124
0.122
0.118
0.180

0.122
0.113
0.122
0.176

-0.001
-0.009
0.004
-0.004

0.531
0.000
0.203
0.613

-0.051
-0.047
-0.055
-0.040

0.000
0.000
0.000
0.003

0.000
0.000
0.000
0.005

0.138
0.130
0.138
0.175

0.149
0.136
0.156
0.165

0.012
0.006
0.018
-0.010

0.002
0.098
0.003
0.275

-0.079
-0.074
-0.083
-0.063

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.003

Quoted Spread ($)
All
2007 – 2009
2010 – 2011
2012 – 2015

247
85
146
16

912
1,363
443
2,795

16,940
30,563
7,181
33,618

0.139
0.136
0.131
0.230

0.087
0.080
0.080
0.186

-0.053
-0.056
-0.052
-0.043

0.000
0.000
0.000
0.000

Quoted Spread (%)
All
2007 – 2009
2010 – 2011
2012 – 2015

247
85
146
16

912
1,363
443
2,795

16,940
30,563
7,181
33,618

0.173
0.165
0.169
0.256

0.106
0.096
0.104
0.183

-0.067
-0.069
-0.065
-0.073

0.000
0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Pilot addition dates 1/26/07, 9/28/07, 3/28/08, and 11/2/09 are
included in the 2007 – 2009 addition date period; Pilot addition dates 2/1/10, 5/3/10, 8/2/10, 1/4/11, and 7/6/11 are included in the 2010 – 2011 period; and Pilot addition dates 1/4/12, 7/3/12, 1/3/13, 7/3/13,
1/3/14, 7/3/14, 1/5/15, and 7/6/15 are included in the 2012 – 2015 period. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month
prior to the month the option class was added to the Pilot (the "pre" month).

Table 6
Univariate Statistics Reported by Underlying Market Capitalization
Unconstrained Matching
Switching
Market Cap
Percentile

N

Average Daily Average Daily
Trade Count
Volume

Pre

Post

Change

Non-Switching
P-Value

Pre

Post

Change

P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Effective Spread ($)
th

95 +
75th – 94th
50th – 74th
Below 50th

69
123

1,279
811

30,296
12,444

0.102
0.107

0.061
0.071

-0.041
-0.036

0.000
0.000

0.085
0.106

0.079
0.106

-0.006
0.000

0.012
0.954

-0.035
-0.035

0.000
0.000

0.000
0.000

38
17

780
449

11,117
8,279

0.106
0.095

0.069
0.066

-0.037
-0.029

0.000
0.001

0.085
0.093

0.084
0.093

-0.001
0.000

0.874
0.941

-0.036
-0.029

0.000
0.003

0.000
0.004

0.098
0.109
0.132
0.160

0.101
0.111
0.158
0.214

0.003
0.002
0.026
0.054

0.281
0.504
0.040
0.083

-0.060
-0.047
-0.077
-0.088

0.000
0.000
0.000
0.011

0.000
0.000
0.000
0.001

0.104
0.137
0.116
0.124

0.099
0.139
0.113
0.122

-0.005
0.002
-0.003
-0.003

0.059
0.479
0.655
0.586

-0.050
-0.053
-0.053
-0.041

0.000
0.000
0.000
0.001

0.000
0.000
0.000
0.002

0.114
0.133
0.167
0.200

0.119
0.136
0.197
0.263

0.005
0.003
0.029
0.062

0.103
0.284
0.048
0.085

-0.078
-0.067
-0.104
-0.112

0.000
0.000
0.000
0.009

0.000
0.000
0.000
0.001

Effective Spread (%)
th

95 +
75th – 94th
50th – 74th
Below 50th

69
123
38
17

1,279
811
780
449

30,296
12,444
11,117
8,279

0.132
0.128
0.163
0.176

0.075
0.084
0.112
0.142

-0.057
-0.045
-0.051
-0.035

0.000
0.000
0.000
0.020

Quoted Spread ($)
th

95 +
75th – 94th
50th – 74th
Below 50th

69
123
38
17

1,279
811
780
449

30,296
12,444
11,117
8,279

0.130
0.143
0.151
0.130

0.074
0.092
0.094
0.086

-0.056
-0.051
-0.057
-0.043

0.000
0.000
0.000
0.000

Quoted Spread (%)
th

95 +
th
th
75 – 94
th
50 – 74th
Below 50th

69
123
38
17

1,279
811
780
449

30,296
12,444
11,117
8,279

0.158
0.162
0.211
0.226

0.085
0.099
0.136
0.176

-0.073
-0.063
-0.074
-0.050

0.000
0.000
0.000
0.011

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Matched pairs of switching and non-switching option classes
are categorized into market capitalization percentiles using the underlying market capitalization of the switching option class at the end of the month prior to the addition date. Market capitalization
percentiles are defined using the stocks listed on the NYSE. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month prior to the
month the option class was added to the Pilot (the "pre" month).

Table 7
Univariate Statistics Reported by Option Class Volume
Unconstrained Matching
Switching
Option Volume
Percentile

N

Average Daily Average Daily
Trade Count
Volume

Pre

Post

Change

Non-Switching
P-Value

Pre

Post

Change

P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Effective Spread ($)
th

98 +
95th – 97th
90th – 94th
Below 90th

49
77

2,461
869

48,820
15,309

0.129
0.105

0.089
0.064

-0.041
-0.041

0.000
0.000

0.102
0.082

0.093
0.077

-0.009
-0.005

0.002
0.011

-0.032
-0.037

0.000
0.000

0.000
0.000

73
48

411
162

6,691
2,600

0.098
0.088

0.064
0.058

-0.034
-0.030

0.000
0.000

0.101
0.106

0.105
0.108

0.004
0.002

0.178
0.620

-0.037
-0.032

0.000
0.000

0.000
0.000

0.108
0.111
0.100
0.142

0.108
0.122
0.107
0.162

0.000
0.011
0.008
0.020

0.989
0.138
0.021
0.067

-0.044
-0.060
-0.055
-0.072

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.124
0.105
0.134
0.138

0.115
0.100
0.139
0.139

-0.009
-0.005
0.006
0.002

0.007
0.018
0.160
0.748

-0.047
-0.055
-0.055
-0.044

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.124
0.135
0.126
0.174

0.125
0.149
0.135
0.197

0.001
0.014
0.009
0.024

0.774
0.096
0.013
0.056

-0.059
-0.083
-0.075
-0.096

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

Effective Spread (%)
th

98 +
95th – 97th
90th – 94th
Below 90th

49
77
73
48

2,461
869
411
162

48,820
15,309
6,691
2,600

0.136
0.135
0.138
0.144

0.092
0.086
0.090
0.092

-0.044
-0.049
-0.048
-0.052

0.000
0.000
0.000
0.000

Quoted Spread ($)
th

98 +
95th – 97th
90th – 94th
Below 90th

49
77
73
48

2,461
869
411
162

48,820
15,309
6,691
2,600

0.165
0.142
0.134
0.117

0.109
0.082
0.085
0.074

-0.057
-0.060
-0.049
-0.042

0.000
0.000
0.000
0.000

Quoted Spread (%)
th

98 +
th
th
95 – 97
th
90 – 94th
Below 90th

49
77
73
48

2,461
869
411
162

48,820
15,309
6,691
2,600

0.163
0.171
0.176
0.182

0.105
0.101
0.109
0.110

-0.058
-0.069
-0.067
-0.072

0.000
0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Matched pairs of switching and non-switching option classes
are categorized into option class volume percentiles using the option class volume of the switching option class during the month prior to the addition date. Option class percentiles are defined using the
universe of option classes on common stock in the LiveVol data. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month prior to
the month the option class was added to the Pilot (the "pre" month).

Table 8
Univariate Statistics Reported by Quoted Price
Unconstrained Matching
Switching
Quoted Price

N

< $1
$1 – $3
$3 – $5
> $5

247
247
245
234

Average Daily Average Daily
Trade Count
Volume

Pre

Post

Change

0.054
0.075
0.122
0.195

0.027
0.046
0.084
0.145

-0.027
-0.029
-0.039
-0.050

Non-Switching
P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Pre

Post

Change

P-Value

0.044
0.066
0.112
0.189

0.044
0.066
0.115
0.185

0.000
0.000
0.004
-0.004

0.761
0.809
0.099
0.291

-0.027
-0.029
-0.042
-0.046

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.259
0.038
0.030
0.021

0.265
0.038
0.031
0.021

0.006
0.000
0.001
-0.001

0.252
0.899
0.105
0.261

-0.135
-0.018
-0.011
-0.006

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.055
0.082
0.147
0.247

0.055
0.083
0.151
0.249

0.000
0.001
0.004
0.002

0.789
0.454
0.034
0.742

-0.039
-0.043
-0.060
-0.070

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.312
0.048
0.039
0.028

0.318
0.049
0.040
0.028

0.006
0.001
0.001
0.000

0.272
0.206
0.041
0.846

-0.179
-0.026
-0.016
-0.009

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

Effective Spread ($)
322
307
102
148

7,690
5,496
1,447
1,720

0.000
0.000
0.000
0.000

Effective Spread (%)
< $1
$1 – $3
$3 – $5
> $5

247
247
245
234

322
307
102
148

7,690
5,496
1,447
1,720

0.324
0.044
0.033
0.022

0.195
0.027
0.022
0.016

-0.129
-0.018
-0.010
-0.006

< $1
$1 – $3
$3 – $5
> $5

247
247
245
234

322
307
102
148

7,690
5,496
1,447
1,720

0.071
0.098
0.166
0.264

0.032
0.056
0.111
0.195

-0.039
-0.042
-0.055
-0.069

< $1
$1 – $3
$3 – $5
> $5

247
247
245
234

322
307
102
148

7,690
5,496
1,447
1,720

0.401
0.058
0.044
0.031

0.228
0.033
0.029
0.022

-0.173
-0.025
-0.015
-0.009

0.000
0.000
0.000
0.000

Quoted Spread ($)
0.000
0.000
0.000
0.000

Quoted Spread (%)
0.000
0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Trades for a given option-class are grouped according to the
bid and ask price. Instances in which the bid and ask fall into separate groups are excluded from the calculation (2.8% of trades). The average daily volume and average daily trade count are calculated on a
per symbol basis and are calculated using the month prior to the month the option class was added to the Pilot (the "pre" month).

Table 9
Univariate Statistics Reported by Expiration Date
Unconstrained Matching
Switching
Expiration Date

N

< 1 week
1 – 2 weeks
2 – 4 weeks
+4 weeks

247
246
247
247

Average Daily Average Daily
Trade Count
Volume

Pre

Post

Change

0.090
0.080
0.078
0.110

0.056
0.048
0.047
0.074

-0.034
-0.031
-0.031
-0.036

Non-Switching
P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Pre

Post

Change

P-Value

0.082
0.073
0.072
0.101

0.083
0.071
0.071
0.101

0.001
-0.002
-0.001
0.000

0.838
0.377
0.627
0.938

-0.034
-0.030
-0.030
-0.036

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.357
0.260
0.191
0.083

0.364
0.264
0.204
0.087

0.007
0.005
0.014
0.004

0.487
0.594
0.038
0.215

-0.117
-0.130
-0.113
-0.045

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.104
0.092
0.093
0.130

0.107
0.092
0.091
0.131

0.003
0.000
-0.001
0.001

0.414
0.958
0.512
0.728

-0.049
-0.045
-0.044
-0.053

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

0.401
0.300
0.230
0.104

0.422
0.313
0.243
0.109

0.021
0.013
0.013
0.005

0.054
0.166
0.059
0.190

-0.152
-0.164
-0.141
-0.063

0.000
0.000
0.000
0.000

0.000
0.000
0.000
0.000

Effective Spread ($)
133
98
146
535

2,242
1,751
2,541
10,412

0.000
0.000
0.000
0.000

Effective Spread (%)
< 1 week
1 – 2 weeks
2 – 4 weeks
+4 weeks

247
246
247
247

133
98
146
535

2,242
1,751
2,541
10,412

0.413
0.330
0.246
0.102

0.303
0.205
0.147
0.061

-0.110
-0.125
-0.100
-0.041

< 1 week
1 – 2 weeks
2 – 4 weeks
+4 weeks

247
246
247
247

133
98
146
535

2,242
1,751
2,541
10,412

0.118
0.104
0.104
0.148

0.071
0.060
0.059
0.095

-0.047
-0.045
-0.045
-0.052

< 1 week
1 – 2 weeks
2 – 4 weeks
+4 weeks

247
246
247
247

133
98
146
535

2,242
1,751
2,541
10,412

0.475
0.388
0.299
0.131

0.344
0.237
0.171
0.073

-0.131
-0.150
-0.128
-0.058

0.000
0.000
0.000
0.000

Quoted Spread ($)
0.000
0.000
0.000
0.000

Quoted Spread (%)
0.000
0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Trades for a given option-class are grouped according to the
time to an option series' expiration. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month prior to the month the option class was
added to the Pilot (the "pre" month).

Table 10
Univariate Statistics Reported by Penny Pilot Addition Date Periods
Unconstrained Matching
Option Classes on ETFs
Switching
Average Daily
Average
Trade Count Daily Volume

Addition Dates

N

All
2007 – 2009
2010 – 2011
2012 – 2015

53
27
19
7

1,149
1,889
239
766

All
2007 – 2009
2010 – 2011
2012 – 2015

53
27
19
7

All
2007 – 2009
2010 – 2011
2012 – 2015

All
2007 – 2009
2010 – 2011
2012 – 2015

Pre

Post

Change

39,965
70,848
5,950
13,169

0.115
0.123
0.105
0.111

0.077
0.073
0.061
0.138

-0.037
-0.050
-0.043
0.027

1,149
1,889
239
766

39,965
70,848
5,950
13,169

0.136
0.120
0.146
0.175

0.099
0.088
0.101
0.138

-0.037
-0.032
-0.045
-0.037

53
27
19
7

1,149
1,889
239
766

39,965
70,848
5,950
13,169

0.154
0.156
0.140
0.183

0.102
0.092
0.078
0.204

-0.052
-0.064
-0.062
0.022

53
27
19
7

1,149
1,889
239
766

39,965
70,848
5,950
13,169

0.183
0.151
0.192
0.281

0.125
0.104
0.126
0.201

-0.058
-0.046
-0.067
-0.080

Non-Switching
P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Pre

Post

Change

P-Value

0.095
0.099
0.096
0.078

0.107
0.105
0.111
0.106

0.012
0.006
0.016
0.028

0.041
0.420
0.199
0.079

-0.050
-0.056
-0.059
-0.001

0.000
0.000
0.000
0.983

0.000
0.000
0.000
0.297

0.117
0.115
0.118
0.121

0.130
0.132
0.132
0.119

0.013
0.017
0.014
-0.002

0.002
0.003
0.080
0.858

-0.050
-0.049
-0.059
-0.035

0.000
0.000
0.000
0.006

0.000
0.000
0.000
0.031

0.124
0.124
0.127
0.112

0.139
0.133
0.146
0.145

0.016
0.008
0.020
0.033

0.032
0.369
0.173
0.087

-0.068
-0.072
-0.082
-0.012

0.000
0.000
0.000
0.830

0.000
0.000
0.000
0.297

0.152
0.145
0.154
0.173

0.166
0.162
0.171
0.168

0.014
0.017
0.016
-0.005

0.005
0.004
0.085
0.762

-0.072
-0.064
-0.083
-0.075

0.000
0.000
0.000
0.009

0.000
0.000
0.000
0.031

Effective Spread ($)
0.000
0.000
0.000
0.455

Effective Spread (%)
0.000
0.000
0.000
0.000

Quoted Spread ($)
0.000
0.000
0.000
0.684

Quoted Spread (%)
0.000
0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Pilot addition dates 1/26/07, 9/28/07, 3/28/08, and 11/2/09 are
included in the 2007 – 2009 addition date period; Pilot addition dates 2/1/10, 5/3/10, 8/2/10, 1/4/11, and 7/6/11 are included in the 2010 – 2011 period; and Pilot addition dates 1/4/12, 7/3/12, 1/3/13, 7/3/13,
1/3/14, 7/3/14, 1/5/15, and 7/6/15 are included in the 2012 – 2015 period. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month
prior to the month the option class was added to the Pilot (the "pre" month).

Table 11
Univariate Statistics Reported by Underlying Market Capitalization
Unconstrained Matching
Option Classes on ETFs
Switching
Market Cap
Percentile

N

Average Daily
Average
Trade Count Daily Volume

Pre

Post

Change

Non-Switching
P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Pre

Post

Change

P-Value

0.081
0.093
0.105

0.085
0.110
0.120

0.004
0.017
0.015

0.519
0.170
0.185

-0.053
-0.058
-0.042

0.016
0.001
0.017

0.000
0.000
0.000

0.095
0.117
0.131

0.108
0.135
0.141

0.012
0.019
0.009

0.044
0.035
0.176

-0.052
-0.052
-0.048

0.000
0.000
0.000

0.000
0.000
0.000

0.104
0.120
0.138

0.105
0.143
0.158

0.001
0.023
0.019

0.888
0.110
0.147

-0.063
-0.080
-0.061

0.007
0.000
0.009

0.000
0.000
0.000

0.119
0.151
0.173

0.131
0.172
0.183

0.012
0.021
0.010

0.056
0.025
0.283

-0.069
-0.075
-0.072

0.000
0.000
0.000

0.000
0.000
0.000

Effective Spread ($)
th

14
17
22

2,213
947
628

103,814
24,294
11,443

0.125
0.102
0.118

0.077
0.061
0.091

-0.049
-0.042
-0.027

th

14
17
22

2,213
947
628

103,814
24,294
11,443

0.126
0.128
0.149

0.086
0.095
0.110

-0.040
-0.033
-0.039

th

14
17
22

2,213
947
628

103,814
24,294
11,443

0.158
0.135
0.166

0.096
0.078
0.124

-0.062
-0.057
-0.042

75 +
th
50 – 74th
Below 50th

0.028
0.000
0.070

Effective Spread (%)
75 +
50 – 74th
Below 50th
th

0.000
0.000
0.000

Quoted Spread ($)
75 +
50 – 74th
Below 50th
th

0.009
0.000
0.040

Quoted Spread (%)
th

75 +
50th – 74th
Below 50th

14
17
22

2,213
947
628

103,814
24,294
11,443

0.165
0.168
0.206

0.107
0.115
0.144

-0.057
-0.053
-0.063

0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Matched pairs of switching and non-switching option classes
are categorized into market capitalization percentiles using the underlying market capitalization of the switching option class at the end of the month prior to the addition date. Market capitalization
percentiles are defined using the stocks listed on the NYSE. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month prior to the
month the option class was added to the Pilot (the "pre" month).

Table 12
Univariate Statistics Reported by Option Class Volume
Unconstrained Matching
Option Classes on ETFs
Switching
Option Volume
Percentile

N

Average Daily
Average
Trade Count Daily Volume

Pre

Post

Change

Non-Switching
P-Value

Difference-in-Differences
Wilcoxon
Diff-in-Diff T-Test Signed-Rank

Pre

Post

Change

P-Value

0.107
0.075
0.105

0.126
0.081
0.119

0.018
0.006
0.015

0.185
0.361
0.228

-0.055
-0.040
-0.056

0.076
0.000
0.000

0.005
0.000
0.000

0.104
0.121
0.124

0.116
0.136
0.136

0.012
0.015
0.012

0.076
0.038
0.138

-0.048
-0.045
-0.058

0.000
0.000
0.000

0.000
0.000
0.000

0.133
0.102
0.137

0.155
0.108
0.158

0.022
0.006
0.021

0.200
0.454
0.138

-0.062
-0.060
-0.080

0.096
0.000
0.000

0.007
0.000
0.000

0.131
0.158
0.162

0.143
0.170
0.180

0.012
0.012
0.017

0.087
0.142
0.094

-0.063
-0.067
-0.085

0.000
0.000
0.000

0.000
0.000
0.000

Effective Spread ($)
th

15
19
19

2,350
1,118
233

111,135
18,709
5,034

0.128
0.114
0.106

0.091
0.079
0.065

-0.036
-0.035
-0.041

th

15
19
19

2,350
1,118
233

111,135
18,709
5,034

0.115
0.141
0.149

0.078
0.111
0.103

-0.037
-0.030
-0.046

th

15
19
19

2,350
1,118
233

111,135
18,709
5,034

0.159
0.162
0.141

0.119
0.108
0.083

-0.040
-0.055
-0.059

95 +
th
90 – 94th
Below 90th

0.173
0.001
0.000

Effective Spread (%)
95 +
90 – 94th
Below 90th
th

0.000
0.000
0.000

Quoted Spread ($)
95 +
90 – 94th
Below 90th
th

0.215
0.000
0.000

Quoted Spread (%)
th

95 +
90th – 94th
Below 90th

15
19
19

2,350
1,118
233

111,135
18,709
5,034

0.148
0.197
0.196

0.097
0.143
0.128

-0.051
-0.054
-0.067

0.000
0.000
0.000

Source: LiveVol; OptionMetrics; CRSP.
Note: Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Matched pairs of switching and non-switching option classes
are categorized into option class volume percentiles using the option class volume of the switching option class during the month prior to the addition date. Option class percentiles are defined using the
universe of option classes on common stock in the LiveVol data. The average daily volume and average daily trade count are calculated on a per symbol basis and are calculated using the month prior to
the month the option class was added to the Pilot (the "pre" month).

Table 13
Penny Pilot Regression Results[1]
Impact on Effective Spreads
Option Classes on Common Stock
[2]

Dec. 2006 – Dec. 2009

[3]

Jan. 2010 – Aug. 2011

Dec. 2011 – Feb. 2016

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.088**

-0.074**

-0.034**

-0.062**

-0.080**

-0.084**

-0.005

-0.006

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.821)

(0.434)

0.831**

0.587**

0.410**

0.286**

0.737**

0.305**

0.958**

0.630**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

-0.015**

-0.012**

-0.006**

-0.005**

-0.010**

-0.006**

-0.019**

-0.011**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.004*

-0.005**

0.007**

-0.002

0.010**

0.005**

0.007**

-0.003*

(0.011)

(0.000)

(0.000)

(0.222)

(0.000)

(0.009)

(0.001)

(0.033)

1,331,185

1,331,185

292,670

292,670

411,698

411,698

626,768

626,768

3,833

3,833

2,625

2,625

2,358

2,358

3,078

3,078

Full Sample
Parameter

Post-Addition Indicator

[6]

Equity Volatility[7]

Log of Option Volume[8]

Log of Underlying Volume[9]

Number of Class/Days
Number of Classes

[4]

[5]

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on effective spreads in the options market. The sample includes data for all
options on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average effective spread. The
average spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for
an option class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Options with non-standard settlement types are excluded. Only trades
with a condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Effective spreads that are greater
than $5 when the price is less than $100 and effective spreads that are greater than $10 otherwise are excluded from the average effective spread calculation. If the underlying stocks traded
below $1 or above $1,000 on any day for which an average effective spread is calculated, the entire option class is removed from the sample. Date and option class fixed effects are used.
Standard errors are estimated by clustering on option class and date. The "Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below the
coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are marked with one asterisk and those that are statistically different from zero
at the 1% significance level are marked with two asterisks.
[2] The model is estimated over the time period from December 1, 2006 to February 29, 2016. The sample includes 38 calendar months of data.
[3] Pilot addition dates 1/26/07, 9/28/07, 3/28/08, and 11/2/09 are included in the December 2006 – December 2009 period.
[4] Pilot addition dates 2/1/10, 5/3/10, 8/2/10, 1/4/11, and 7/6/11 are included in the January 2010 – August 2011 period.
[5] Pilot addition dates 1/4/12, 7/3/12, 1/3/13, 7/3/13, 1/3/14, 7/3/14, 1/5/15, and 7/6/15 are included in the December 2011 – February 2016 period.
[6] An indicator variable that equals one in the post-addition period and zero otherwise.
[7] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[8] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[9] The natural log of the volume for the underlying stock.

Table 14
Penny Pilot Regression Results[1]
Impact on Quoted Spreads
Option Classes on Common Stock
[2]

Dec. 2006 – Dec. 2009

[3]

Jan. 2010 – Aug. 2011

Dec. 2011 – Feb. 2016

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.161**

-0.137**

-0.053**

-0.091**

-0.122**

-0.119**

-0.037

-0.049**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.239)

(0.000)

0.907**

0.705**

0.441**

0.331**

0.812**

0.360**

1.048**

0.769**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

-0.026**

-0.021**

-0.008**

-0.008**

-0.015**

-0.012**

-0.034**

-0.023**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.009**

-0.005**

0.008**

-0.002

0.014**

0.005*

0.014**

-0.005*

(0.000)

(0.001)

(0.000)

(0.204)

(0.000)

(0.025)

(0.000)

(0.023)

1,331,123

1,331,123

292,668

292,668

411,691

411,691

626,715

626,715

3,832

3,832

2,625

2,625

2,358

2,358

3,077

3,077

Full Sample
Parameter

Post-Addition Indicator

[6]

Equity Volatility[7]

Log of Option Volume[8]

Log of Underlying Volume[9]

Number of Class/Days
Number of Classes

[4]

[5]

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on quoted spreads in the options market. The sample includes data for all
options on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average quoted spread. The
average spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for
an option class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Options with non-standard settlement types are excluded. Only trades
with a condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Quoted spreads that are greater
than $5 when the price is less than $100 and quoted spreads that are greater than $10 otherwise are excluded from the average quoted spread calculation. If the underlying stocks traded
below $1 or above $1,000 on any day for which an average quoted spread is calculated, the entire option class is removed from the sample. Date and option class fixed effects are used.
Standard errors are estimated by clustering on option class and date. The "Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below the
coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are marked with one asterisk and those that are statistically different from zero
at the 1% significance level are marked with two asterisks.
[2] The model is estimated over the time period from December 1, 2006 to February 29, 2016. The sample included 38 calendar months of data.
[3] Pilot addition dates 1/26/07, 9/28/07, 3/28/08, and 11/2/09 are included in the December 2006 – December 2009 period.
[4] Pilot addition dates 2/1/10, 5/3/10, 8/2/10, 1/4/11, and 7/6/11 are included in the January 2010 – August 2011 period.
[5] Pilot addition dates 1/4/12, 7/3/12, 1/3/13, 7/3/13, 1/3/14, 7/3/14, 1/5/15, and 7/6/15 are included in the December 2011 – February 2016 period.
[6] An indicator variable that equals one in the post-addition period and zero otherwise.
[7] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[8] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[9] The natural log of the volume for the underlying stock.

Table 15
Penny Pilot Regression Results[1]
Impact on Effective Spreads
Unconstrained Matching[2]
Full Sample[3]
Parameter

Post-Switch Indicator

[7]

Equity Volatility[8]

Log of Option Volume[9]

Log of Underlying Volume[10]

Number of Class/Days
Number of Classes

Dec. 2006 – Dec. 2009[4]

Jan. 2010 – Aug. 2011[5]

Dec. 2011 – Aug. 2015[6]

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.036**

-0.058**

-0.034**

-0.059**

-0.040**

-0.060**

-0.011*

-0.032**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.036)

(0.001)

0.360**

-0.200

0.286**

-0.194**

0.391**

-0.251

0.362**

0.158

(0.000)

(0.110)

(0.000)

(0.009)

(0.000)

(0.196)

(0.002)

(0.206)

0.002**

-0.001

0.002**

0.000

0.002*

-0.002

0.001

0.016**

(0.004)

(0.439)

(0.008)

(0.959)

(0.022)

(0.234)

(0.653)

(0.005)

0.008**

0.009

0.010**

0.009*

0.006**

0.010

0.018**

-0.018

(0.000)

(0.074)

(0.000)

(0.027)

(0.001)

(0.148)

(0.001)

(0.236)

21,025

21,025

7,368

7,368

12,369

12,369

1,288

1,288

494

494

170

170

292

292

32

32

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on effective spreads in the options market. The sample includes data for options
on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average effective spread. The average
spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for an option
class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Option classes on common stock are identified using share code 10 and 11 in the
CRSP data. Options with non-standard settlement types are excluded. Only trades with a condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to
regular trades and intermarket sweep orders. Effective spreads that are greater than $5 when the price is less than $100 and effective spreads that are greater than $10 otherwise are
excluded from the average effective spread calculation. If the underlying stocks traded below $1 or above $1,000 on any day for which an average effective spread is calculated, the entire
option class is removed from the sample. Date and option event fixed effects are used. Standard errors are estimated by clustering on option class-event and date. The "Permno" in CRSP is
used to identify option classes over time. P-values are reported in parentheses below the coefficient estimates. Coefficient estimates that are statistically different from zero at the 5%
significance level are marked with one asterisk and those that are statistically different from zero at the 1% significance level are marked with two asterisks.
[2] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume.
[3] The model is estimated over the time period from December 1, 2006 to August 31, 2015.
[3] Pilot addition dates 1/26/07, 9/28/07, 3/28/08, and 11/2/09 are included in the December 2006 – December 2009 period.
[4] Pilot addition dates 2/1/10, 5/3/10, 8/2/10, 1/4/11, and 7/6/11 are included in the January 2010 – August 2011 period.
[5] Pilot addition dates 1/4/12, 7/3/12, 1/3/13, 7/3/13, 1/3/14, 7/3/14, 1/5/15, and 7/6/15 are included in the December 2011 – August 2015 period.
[7] An indicator variable that equals one in the post-switch period and zero otherwise.
[8] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[9] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[10] The natural log of the volume for the underlying stock.

Table 16
Penny Pilot Regression Results[1]
Impact on Quoted Spreads
Unconstrained Matching[2]
[3]

Dec. 2006 – Dec. 2009

[4]

Jan. 2010 – Aug. 2011

Dec. 2011 – Feb. 2015

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.052**

-0.078**

-0.048**

-0.075**

-0.056**

-0.082**

-0.036**

-0.062**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.393**

-0.195

0.274**

-0.228**

0.439**

-0.247

0.405*

0.313*

(0.000)

(0.161)

(0.002)

(0.003)

(0.000)

(0.253)

(0.011)

(0.021)

0.000

-0.004*

0.001

-0.001

0.000

-0.004*

-0.002

0.003

(0.698)

(0.019)

(0.256)

(0.452)

(0.795)

(0.023)

(0.759)

(0.600)

0.011**

0.011*

0.014**

0.011**

0.008**

0.012

0.029**

-0.009

(0.000)

(0.032)

(0.000)

(0.009)

(0.000)

(0.105)

(0.000)

(0.321)

21,025

21,025

7,368

7,368

12,369

12,369

1,288

1,288

494

494

170

170

292

292

32

32

Full Sample
Parameter

Post-Switch Indicator

[7]

Equity Volatility[8]

Log of Option Volume[9]

Log of Underlying Volume[10]

Number of Class/Days
Number of Classes

[5]

[6]

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on quoted spreads in the options market. The sample includes data for options
on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average quoted spread. The average
spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for an option
class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Option classes on common stock are identified using share code 10 and 11 in the
CRSP data. Options with non-standard settlement types are excluded. Only trades with a condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to
regular trades and intermarket sweep orders. Quoted spreads that are greater than $5 when the price is less than $100 and quoted spreads that are greater than $10 otherwise are excluded
from the average quoted spread calculation. If the underlying stocks traded below $1 or above $1,000 on any day for which an average quoted spread is calculated, the entire option class is
removed from the sample. Date and option event fixed effects are used. Standard errors are estimated by clustering on option class-event and date. The "Permno" in CRSP is used to identify
option classes over time. P-values are reported in parentheses below the coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are
marked with one asterisk and those that are statistically different from zero at the 1% significance level are marked with two asterisks.
[2] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume.
[3] The model is estimated over the time period from December 1, 2006 to August 31, 2015.
[3] Pilot addition dates 1/26/07, 9/28/07, 3/28/08, and 11/2/09 are included in the December 2006 – December 2009 period.
[4] Pilot addition dates 2/1/10, 5/3/10, 8/2/10, 1/4/11, and 7/6/11 are included in the January 2010 – August 2011 period.
[5] Pilot addition dates 1/4/12, 7/3/12, 1/3/13, 7/3/13, 1/3/14, 7/3/14, 1/5/15, and 7/6/15 are included in the December 2011 – August 2015 period.
[7] An indicator variable that equals one in the post-switch period and zero otherwise.
[8] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[9] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[10] The natural log of the volume for the underlying stock.

Table 17
Penny Pilot Regression Results[1]
Impact on Effective Spreads
Unconstrained Matching[2]
Market Capitalization Percentile[3]
th

th

95 and Above
Parameter

Post-Switch Indicator[4]

[5]

Equity Volatility

[6]

Log of Option Volume

Log of Underlying Volume[7]

Number of Class/Days
Number of Classes

th

th

75 – 94

th

th

50 – 74

Below 50

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.035**

-0.060**

-0.036**

-0.047**

-0.037**

-0.076**

-0.032**

-0.087**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.602**

-0.083

0.407**

-0.056

0.334**

-0.536

0.286**

-0.097

(0.000)

(0.378)

(0.000)

(0.300)

(0.000)

(0.085)

(0.000)

(0.781)

0.002**

0.001

0.002*

-0.001

0.001

0.000

0.001

-0.015

(0.009)

(0.439)

(0.013)

(0.542)

(0.799)

(0.959)

(0.568)

(0.150)

0.009**

0.007**

0.010**

0.007*

0.007

0.034*

0.001

-0.005

(0.000)

(0.004)

(0.000)

(0.010)

(0.104)

(0.027)

(0.792)

(0.664)

5,923

5,923

10,465

10,465

3,198

3,198

1,439

1,439

138

138

246

246

76

76

34

34

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on effective spreads in the options market. The sample includes data for options
on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average effective spread. The average
spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for an option
class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Options with non-standard settlement types are excluded. Only trades with a
condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Effective spreads that are greater than $5
when the price is less than $100 and effective spreads that are greater than $10 otherwise are excluded from the average effective spread calculation. If the underlying stocks traded below
$1 or above $1,000 on any day for which an average effective spread is calculated, the entire option class is removed from the sample. Date and option event fixed effects are used.
Standard errors are estimated by clustering on option class-event and date. The "Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below
the coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are marked with one asterisk and those that are statistically different from
zero at the 1% significance level are marked with two asterisks.
[2] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume.
[3] Matched pairs of switching and non-switching option classes are categorized into market capitalization percentiles using the underlying market capitalization of the switching option class
at the end of the month prior to the addition date. Market capitalization percentiles are defined using the stocks listed on the NYSE.
[4] An indicator variable that equals one in the post-switch period and zero otherwise.
[5] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[6] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[7] The natural log of the volume for the underlying stock.

Table 18
Penny Pilot Regression Results[1]
Impact on Quoted Spreads
Unconstrained Matching[2]
Market Capitalization Percentile[3]
th

th

75 – 94th

95 and Above
Parameter

Post-Switch Indicator[4]

Equity Volatility[5]

Log of Option Volume[6]

[7]

Log of Underlying Volume

Number of Class/Days
Number of Classes

50th – 74th

Below 50th

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.050**

-0.078**

-0.054**

-0.066**

-0.053**

-0.101**

-0.044**

-0.112**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.626**

-0.116

0.414**

-0.048

0.454**

-0.457

0.338**

-0.150

(0.000)

(0.224)

(0.000)

(0.452)

(0.000)

(0.167)

(0.000)

(0.712)

0.001

0.000

0.001

-0.002

-0.001

-0.004

-0.001

-0.022*

(0.222)

(0.993)

(0.642)

(0.105)

(0.656)

(0.446)

(0.713)

(0.048)

0.012**

0.009**

0.014**

0.008**

0.008

0.035*

0.001

0.002

(0.000)

(0.000)

(0.000)

(0.010)

(0.098)

(0.019)

(0.811)

(0.891)

5,923

5,923

10,465

10,465

3,198

3,198

1,439

1,439

138

138

246

246

76

76

34

34

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on quoted spreads in the options market. The sample includes data for options
on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average quoted spread. The average
spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for an option
class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Options with non-standard settlement types are excluded. Only trades with a
condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Quoted spreads that are greater than $5
when the price is less than $100 and quoted spreads that are greater than $10 otherwise are excluded from the average quoted spread calculation. If the underlying stocks traded below $1
or above $1,000 on any day for which an average quoted spread is calculated, the entire option class is removed from the sample. Date and option class-event fixed effects are used.
Standard errors are estimated by clustering on option class-event and date. The "Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below
the coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are marked with one asterisk and those that are statistically different from
zero at the 1% significance level are marked with two asterisks.
[2] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume.
[3] Matched pairs of switching and non-switching option classes are categorized into market capitalization percentiles using the underlying market capitalization of the switching option class
at the end of the month prior to the addition date. Market capitalization percentiles are defined using the stocks listed on the NYSE.
[4] An indicator variable that equals one in the post-switch period and zero otherwise.
[5] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[6] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[7] The natural log of the volume for the underlying stock.

Table 19
Penny Pilot Regression Results[1]
Impact on Effective Spreads
Unconstrained Matching[2]
Option Volume Percentile[3]
th

th

98 and Above
Parameter

Post-Switch Indicator[4]

[5]

Equity Volatility

[6]

Log of Option Volume

Log of Underlying Volume[7]

Number of Class/Days
Number of Classes

th

th

95 – 97

th

th

90 – 94

Below 90

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.033**

-0.045**

-0.038**

-0.061**

-0.037**

-0.055**

-0.034**

-0.070**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.374**

-0.054

0.277**

-0.307

0.422**

0.051

0.368**

-0.423

(0.000)

(0.502)

(0.000)

(0.129)

(0.000)

(0.443)

(0.000)

(0.273)

0.003*

0.001

0.003**

0.001

0.003*

0.002

-0.001

-0.005

(0.039)

(0.511)

(0.002)

(0.575)

(0.026)

(0.241)

(0.599)

(0.106)

0.012**

0.005

0.006*

0.002

0.007**

0.003

0.006

0.023

(0.000)

(0.236)

(0.047)

(0.620)

(0.000)

(0.470)

(0.093)

(0.120)

4,208

4,208

6,609

6,609

6,156

6,156

4,052

4,052

98

98

154

154

146

146

96

96

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on effective spreads in the options market. The sample includes data for options
on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average effective spread. The average
spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for an option
class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Options with non-standard settlement types are excluded. Only trades with a
condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Effective spreads that are greater than $5
when the price is less than $100 and effective spreads that are greater than $10 otherwise are excluded from the average effective spread calculation. If the underlying stocks traded below
$1 or above $1,000 on any day for which an average effective spread is calculated, the entire option class is removed from the sample. Date and option class-event fixed effects are used.
Standard errors are estimated by clustering on option class-event and date. The "Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below
the coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are marked with one asterisk and those that are statistically different from
zero at the 1% significance level are marked with two asterisks.
[2] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume.
[3] Matched pairs of switching and non-switching option classes are categorized into option class volume percentiles using the option class volume of the switching option class during the
month prior to the addition date. Option class percentiles are defined using the universe of option classes on common stock in the LiveVol data.
[4] An indicator variable that equals one in the post-switch period and zero otherwise.
[5] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[6] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[7] The natural log of the volume for the underlying stock.

Table 20
Penny Pilot Regression Results[1]
Impact on Quoted Spreads
Unconstrained Matching[2]
Option Volume Percentile[3]
th

th

95 – 97th

98 and Above
Parameter

Post-Switch Indicator[4]

Equity Volatility[5]

Log of Option Volume[6]

[7]

Log of Underlying Volume

Number of Class/Days
Number of Classes

90th – 94th

Below 90th

Dollar

Percent

Dollar

Percent

Dollar

Percent

Dollar

Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

-0.048**

-0.059**

-0.056**

-0.084**

-0.055**

-0.075**

-0.045**

-0.092**

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

0.415**

-0.025

0.266**

-0.365

0.487**

0.090

0.421**

-0.368

(0.000)

(0.762)

(0.001)

(0.123)

(0.000)

(0.281)

(0.001)

(0.362)

0.002

0.000

0.002

0.000

0.001

-0.001

-0.003

-0.008**

(0.156)

(0.928)

(0.083)

(0.920)

(0.559)

(0.722)

(0.115)

(0.009)

0.015**

0.006

0.010**

0.003

0.010**

0.006

0.008*

0.026

(0.000)

(0.148)

(0.009)

(0.529)

(0.000)

(0.186)

(0.049)

(0.094)

4,208

4,208

6,609

6,609

6,156

6,156

4,052

4,052

98

98

154

154

146

146

96

96

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on quoted spreads in the options market. The sample includes data for options
on common stock that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average quoted spread. The average
spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average spread for an option
class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Options with non-standard settlement types are excluded. Only trades with a
condition code in 0, 18, 95, and 106 are included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Quoted spreads that are greater than $5
when the price is less than $100 and quoted spreads that are greater than $10 otherwise are excluded from the average quoted spread calculation. If the underlying stocks traded below $1
or above $1,000 on any day for which an average quoted spread is calculated, the entire option class is removed from the sample. Date and option class-event fixed effects are used.
Standard errors are estimated by clustering on option class-event and date. The "Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below
the coefficient estimates. Coefficient estimates that are statistically different from zero at the 5% significance level are marked with one asterisk and those that are statistically different from
zero at the 1% significance level are marked with two asterisks.
[2] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume.
[3] Matched pairs of switching and non-switching option classes are categorized into option class volume percentiles using the option class volume of the switching option class during the
month prior to the addition date. Option class percentiles are defined using the universe of option classes on common stock in the LiveVol data.
[4] An indicator variable that equals one in the post-switch period and zero otherwise.
[5] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[6] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[7] The natural log of the volume for the underlying stock.

Table 21
Penny Pilot Regression Results[1]
Option Classes on ETFs
Full Sample[2]
Parameter

Post-Switch Indicator[4]

Equity Volatility[5]

Log of Option Volume[6]

Log of Underlying Volume[7]

Number of Class/Days
Number of Classes

Effective Spread
Dollar
Percent

Unconstrained Matching[3]

Quoted Spread
Dollar
Percent

Effective Spread
Dollar
Percent

Quoted Spread
Dollar
Percent

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

0.008

-0.032**

-0.045*

-0.093**

-0.049**

-0.050**

-0.066**

-0.072**

(0.664)

(0.000)

(0.034)

(0.000)

(0.000)

(0.000)

(0.000)

(0.000)

2.293**

0.149

2.331**

-0.055

1.067**

0.190

1.304**

0.097

(0.000)

(0.144)

(0.000)

(0.682)

(0.000)

(0.120)

(0.000)

(0.501)

-0.023**

-0.014**

-0.031**

-0.021**

0.001

0.001

0.001

-0.001

(0.000)

(0.000)

(0.000)

(0.000)

(0.399)

(0.782)

(0.729)

(0.659)

-0.029**

-0.010**

-0.040**

-0.011**

0.003

-0.008**

0.001

-0.011**

(0.000)

(0.000)

(0.000)

(0.000)

(0.602)

(0.001)

(0.860)

(0.000)

194,694

194,694

194,659

194,659

4,537

4,537

4,537

4,537

693

693

693

693

106

106

106

106

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.
[1] This table reports results from a panel regression estimating the effects of switching to trading in pennies on quoted and effective spreads in the options market. The sample includes data
for all options on ETFs that traded in the calendar month before and calendar month after the Penny Pilot addition dates. The dependent variable is the average quoted or average effective
spread. The average spread is calculated by (1) calculating the volume weighted spread for an option series-day and then (2) equally weighting across option series to calculate the average
spread for an option class-day. Canceled trades and trades that were executed during a locked or crossed market are excluded. Only trades with a condition code in 0, 18, 95, and 106 are
included. Condition codes 0, 18, 95, and 106 correspond to regular trades and intermarket sweep orders. Quoted spreads that are greater than $5 when the price is less than $100 and
quoted spreads that are greater than $10 otherwise are excluded from the average quoted spread calculation. The same restrictions are used to calculate average effective spreads. If the
underlying ETF traded below $1 or above $1,000 on any day for which an average quoted spread or effective spread is calculated, the entire option class is removed from the sample. The
"Permno" in CRSP is used to identify option classes over time. P-values are reported in parentheses below the coefficient estimates. Coefficient estimates that are statistically different from
zero at the 5% significance level are marked with one asterisk and those that are statistically different from zero at the 1% significance level are marked with two asterisks.
[2] All option classes on common stock for which LiveVol has data are included. Date and option class fixed effects are used. Standard errors are estimated by clustering on option class and
date.
[3] Each switching option class is matched with a non-switching option class based on underlying market capitalization and option volume. Date and option class-event fixed effects are used.
Standard errors are estimated by clustering on option class-event and date.
[4] An indicator variable that equals one in the post-switch period and zero otherwise. Note that under unconstrained matching, a switching option class may match with an option class that
is already in the Pilot, in which case the option class that is already in the Pilot, acting as the control option class, has a value of zero in the pre-switch and post-switch period.
[5] The underlying stock volatility as measured by the high price minus the low price divided by the closing price.
[6] The natural log of the option class volume. The option class volume excludes canceled trades and only includes trades with a condition code in 0, 18, 95, and 106.
[7] The natural log of the volume for the underlying stock.

Table 22
Liquidity Metrics for In-Pilot Option Classes and Control Samples
February 2016
Daily Volume of Option Class (Contracts)
Number of Number of Clusters
for Matching with
Option
Classes
Replacement[1]

Market Cap of Underlying Stock (Millions)

Option Volume
Quartile for In-Pilot
Option Classes

Percentile Range
in Universe of
Option Classes

First Quartile

41.4% - 88.3%

56

53

1,044

1,053

825

10,963

10,434

8,789

Second Quartile

88.4% - 95.0%

57

41

3,906

3,734

2,122

27,821

21,220

14,311

Third Quartile

95.0% - 97.7%

57

25

10,005

6,208

2,841

50,927

37,125

19,441

Fourth Quartile

97.7% - 100.0%

56

23

53,504

10,977

4,990

107,613

71,809

24,334

In-Pilot

With
Without
Replacement[2] Replacement[3]

In-Pilot

With
Without
Replacement[2] Replacement[3]

Sources: LiveVol; CRSP; OptionMetrics; ISE Penny Pilot Addition Dates.

[1] The number of unique control option classes in matching with replacement. In matching with replacement, an in-Pilot option class can match with any number of switching option classes.
[2] Each in-Pilot option class is matched to an out-of-Pilot option classes based on underlying market capitalization, underlying price, and option volume. Matching is completed with replacement,
i.e. an out-of-Pilot option class can match with any number of in-Pilot option classes.
[3] Each in-Pilot option class is matched to an out-of-Pilot option classes based on underlying market capitalization, underlying price, and option volume. Matching is completed without
re

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Asec%3A6aebd220700f155a. Public record. Not legal advice.
