A) If I had a partial fill (e.g. 30 options) for an order of 100 options, and start to close out the 30 options at the ask price B) The options at the ask price are being bought one option at a time, and they are also selling me at the remaining bid one option at a time, will this count as multiple fills for PDT purposes? Apparently, this is what Penson seems to be claiming...
(I'm not the rulebook here but I think...) Depends on how you entered the order. If you put in an order to buy 100 shares/contracts (whatever) and you get 5 partial fills to complete your order that does not count as five purhcases. It's round trips, not buys or sells. You can buy 300 stocks just as long as you don't make more than 4 round trips in 5 days. If you get partials on the way in and partials on the way out but you enter the whole amount in the order then that is one order. If you get partialed on the way in and close only the partial before the remainder of the opening position is filled then you would be entering two orders. Example: buy to open 100 contracts, get filled 30 contracts, 70 contracts sitting in queue, if you enter sell to close 30 contracts that 30 contracts would be one round trip. If you are later filled the 70 then you would consider closing out of that a second round trip. If you buy 100 to open and sell 100 to close I don't think your system will allow you to sell 100 to close on a position that isn't yet filled right?
you did not bring down the middle case, i.e. if he puts in the sell order which is getting partial fills while he simultaneously is continuing to get partial buys. One order to buy is placed and one to close, but the fills are occurring one at a time.