Umbra Applied Technologies Group Inc (UATG)

[Gordo56]

When it comes to T-trades the only requirement of MM's by FINRA is that they must report all trades within 2 days or before the open next trading day (Trade+2/T+2). They are not required to do so when the actual trade occurs.

To avoid creating “an unbalanced market”, MM's often do not report certain trades during the day to the public and then use a T Trade not to “scare” investors into thinking a market for that stock is going in one direction or the other at the spurring of one large investor.

If a market maker wants to accumulate a large amount of a stock in one trading day, that market maker may actually not report any of the trades that occurred until the trading day has ended so as not to alert the market to the collection. This is completely legal under the FINRA rules of the OTC Markets so long as the trade is reported within a day.

To execute a "Market on Close” order, a MM may have an order to purchase the stock at a certain price at the end of the trading day. This is the most unlikely scenario because it needs to be assured that someone selling the stock and someone buying that stock are agreeing upon a price. This is a "cross" and is indicative of manipulation IMO by someone

The T Trade that the public sees is nothing more than one or all of the above scenarios. The T Trade reported at the end of the day or T+2 can be from one MM or many involved MM's. It can be a single purchase price but is usually an average of all of the previously unreported purchases from that business day.

In addition MM's are not required to honor their offer price. The OTC market is essentially a “best offer” market. If a buyer meets the asking price for a security, the MM can, and often does, decide to rescind the offer, not sell the security and adjust the selling price.

For more specifics:

http://www.finra.org/industry/notices/17-19