It seems to me there is a serious loophole that needs to be closed and could be rather easy to do so. When new shares are created and they want to sell on the open market, they have to enter the electronic system. This is where the TA comes in, correct? The TA has a running total of the share count. When existing shares are bot/sld on the open market the TA already has an electronic accounting of those shareholders, correct? Well, when a sale occurs and the seller's shares are not yet in the system that is when the running total increases and that data could easily be automatically disseminated to regulators, and data outlets like otcmarkets that publish the share count for the public's benefit. In this digital world it is inconceivable why this can't be done quickly and automatically.