As someone who has actually seen the scenario described above play out, I'm not so sure: stock doesn't move for minutes at a low volume time of day, the moment I place my limit order the price is suddenly higher than my limit; rinse and repeat. I've seen this happen enough times to make me believe Reg NMS is just another regulation they've found a plausible deniability around (BTW, before you tell me "prices going up when you place a big order is how the market works", I've tested this with 100 share orders, so there was no order split going on. I still got priced out.)