AccessTel (ATEL)

[myDDdotcom]

OT: Your overextending this case, read it more carefully:

Insider trading regulations not only applies to the typical insider, but it also applies to employees, such as engineers, accountants or others who acquire material information from a corporate source.

You are extending others beyond the internal reference of the sentence, to mean any old other, instead of the other implied, i.e., under employees. Tsk, tsk... this case is actually very stringent, n/a to what you are attempting to apply it to here, as being it's an OTC, there is no such designation as the typical insider (like say for instance an analyst or specialist that gets inside looks at the books), but then, you'd like to claim any information under other, sorry, that's too sloppy.
In grad school I did learn that law is a tricky linguistic gambit, easy to mistake a loophole for a noose.... and vice versa.
Even if I were to grant that you had a case here that could be applied to OTC's, so what! It's irrelevant to the reality of doing DD and investing in the OTC (imagine the SEC proving what I should know), that would be some deliberation!
The only thing anyone ever gets nailed for in the OTC is deliberately and misleadingly pumping to dump, anything other than that is just too ordinary for the SEC to bother.

imo