This is definitely true, and both journalists and individuals often glance over things like trading fees versus best execution without regard to investing style or intent.

If I'm a retail investor and I'm buying large-cap US stocks, window trading my 50 lot of AAPL at 11 AM for free when the market is $0.01 wide is significantly better than buying $5 commissions. If I have 10,000 shares to buy in a small cap company, these types of systems will usually dump the order off into the market since the system will have few crossing orders. This likely will be a lot more expensive than $5.