So I was correct FINRA is also a clearing service, like Penson and the like. So they do link data to the DTCC as the central location for info. All clearing houses report to the DTCC their credits and debits for each security on a daily basis, SO OTC link is like tier 1 for market makers, on the OTC 2 tier trading system and OTC markets is tier 2 public. created OTC Link a registered Broker Dealer back in 2012, it is an ATS (Alternative Trade System),