The SEC defines a “Form T Trade” a “trade reporting form used by broker-dealer members of the Financial Industry Regulatory Authority, Inc. (FINRA) to report equity trades executed either in the OTC market or during extended hours trading.
If you contact the SEC, they will confirm that "after hours” trades do not exist in the Pinks.
The only requirement of market makers by FINRA is that they must report all trades in a day (before the market opens again). They are not required to do so when the actual trade occurs.
Market makers often do not report certain trades during the day to the public. They then use a T Trade - which is completely legal under the FINRA rules of the OTC Markets - so long as the trade is reported at the end of the day.
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