True insiders file a form 4. Debt holders aren't required to disclose. T trades in OTC do many times indicate allowed manipulation. A common occurrence is for MMs to accumulate all shares throughout the day and report them all at once with an average price at the close of the day. MMs can also choose not to post during the day to avoid creating an unbalanced market and post at or just after close. MOC's can happen too, but need a specific buyer and seller so it's less common. Usually, whomever is liquidating is directing the MM to post the average in one lump sum as a t trade. Debt holders don't care about pps really, they just want their money back and their profit is built in due to their discount and anti dilution provisions normally. It is shifty, but allowed.
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