Costs of Trading

Quick Answer

Commissions are a separately charged, explicit cost of agency trades; markups and markdowns are the cost of principal trades, embedded in the customer's price rather than always itemized separately. FINRA's 5% markup policy is a flexible fairness guideline (not a cap) that also covers agency commissions, though not municipal securities. The bid-ask spread is an implicit cost that can apply when crossing it. Best execution requires broker-dealers to seek the most favorable terms reasonably available, and it applies to both principal and agency transactions.

You now know the order types, account structures, and who facilitates trades. The final piece is understanding what trading actually costs. Commissions are explicit (separately charged); markups/markdowns are embedded in the price the customer pays, sometimes with separate confirmation disclosure; and other costs are implicit (built into the price you receive).


Explicit Costs

Commissions

  • Fees charged by brokers for executing trades on behalf of clients
  • Apply to agency transactions (the broker-dealer acts as an intermediary, not a counterparty)
  • The amount may be a flat fee, a per-share charge, or a percentage of the trade value
  • Must be disclosed on trade confirmations

Markups and Markdowns

  • Apply to principal transactions (the broker-dealer trades from its own inventory)
  • Markup: The amount added to the market price when the dealer sells to a customer
  • Markdown: The amount subtracted from the market price when the dealer buys from a customer
  • Must be fair and reasonable; the markup is embedded in the customer's net price rather than always itemized separately, though certain debt-security transactions trigger specific confirmation disclosure

FINRA's 5% Markup Policy:

  • FINRA's 5% markup policy provides a guideline (not a hard rule or ceiling) that markups, markdowns, and also agency commissions generally should not exceed 5% of the prevailing market price
  • The policy does not govern municipal securities, which are priced under separate MSRB fair-pricing standards
  • Factors that may justify higher or lower markups include:
    • The type of security (equity vs. debt)
    • Availability of the security in the market
    • Dollar amount of the transaction
    • The broker-dealer's pattern of markups
    • The nature of the firm's business

Exam Tip: Gotchas

  • The 5% markup policy is a guideline, not a rule. It is not a ceiling; markups above 5% are not automatically violations, and markups below 5% are not automatically reasonable.
  • A firm charges a markup or a commission on a given trade, never both. If acting as principal, the cost is a markup/markdown. If acting as agent, the cost is a commission.

Implicit Costs

Bid-Ask Spread

  • The spread is the difference between the bid (what buyers will pay) and the ask (what sellers will accept)
  • This is an implicit cost because no separate fee is charged; if the investor buys at the ask and immediately sells at an unchanged bid, the round trip loses one full spread
  • Actual cost depends on the execution price relative to prevailing quotes: an order can receive price improvement or execute at another price rather than crossing the full quoted spread
  • Wider spreads = higher potential implicit costs = less liquid securities
  • Narrower spreads = lower potential implicit costs = more liquid securities

Exam Tip: Gotchas

  • The bid-ask spread is a real potential cost even though it does not appear as a separate line item. On a round-trip trade at unchanged quotes, the investor loses one full spread total (not the spread twice).
  • Payment for order flow creates a conflict of interest. The broker may prioritize the market maker that pays the highest rebate over the one providing the best price for the customer.

Best Execution Obligation

  • Best execution is the obligation of broker-dealers to seek the most favorable terms reasonably available for customer orders
  • Governed by FINRA's best-execution rule
  • Applies to both principal and agency transactions
  • Factors considered when evaluating best execution include, among others:
    • Price improvement opportunities
    • Speed of execution
    • Likelihood of execution
    • Execution size and transaction costs
    • Customer needs and order-routing/payment-for-order-flow arrangements

Best execution does not mean the absolute best price on every trade. It means the broker-dealer must use reasonable diligence to find the best market for the security, considering all relevant factors.

Exam Tip: Gotchas

  • Best execution applies to both principal and agency transactions, not just agency. A common wrong answer limits best execution to broker (agency) transactions only. It applies regardless of capacity.

Costs Comparison

Cost TypeApplies ToExplicit or ImplicitWho Bears It
CommissionAgency (broker) tradesExplicit (separately charged)Customer
Markup/MarkdownPrincipal (dealer) tradesEmbedded in price (sometimes separately disclosed)Customer
Bid-ask spreadTrades that cross the quoted spreadImplicitCustomer

What Should You Check on Exam Day?

  • Commissions apply to agency trades and must be disclosed; markups/markdowns apply to principal trades and must be fair and reasonable.
  • FINRA's 5% markup policy is a guideline (not a hard ceiling) that also covers agency commissions but not municipal securities; markups above 5% aren't automatically violations, and markups below 5% aren't automatically reasonable.
  • The bid-ask spread is an implicit potential cost, even though it doesn't appear as a line item; a round trip at unchanged quotes loses one full spread total, not the spread twice.
  • Payment for order flow must be disclosed and creates a potential conflict of interest.
  • Best execution requires reasonable diligence across factors like price, speed, likelihood of execution, and execution size, and it applies to both principal and agency transactions, not just agency.