Here’s some DD someone posted that can clarify things for some here and It could certainly apply to DBMM:
XXX OTC & Short Exempt Trading
As some of you may have heard we have discovered short sellers hiding their shorts by OFF EXCHANGE TRADING or better known as OVER THE COUNTER (OTC) TRADING. OTC trading allows smaller companies who may not meet the requirements to be listed on an exchange to still be able to trade shares of their company. In addition to that trades happen directly between two parties without the supervision or regulation of an exchange. Larger companies that are already listed on an exchange have been known to Over The Counter Trade due to there being no regulation and no supervision on OTC Trading.
FINRA, a private regulator contracted by the government to regulate certain aspects of the market keeps track of OTC trade data. Though FINRA is considered a regulator they don't really do any regulating, it seems all they do is help track data. Each day they publish data on short selling volume for On Exchange Trading as well as Off Exchange Trading (OTC). They also track what is called Short Exempt Volume. What is Short Exempt?
Short Exempt simply allows shorters to short a stock on the down-tick despite SSR being in place, rendering SSR useless. What allows them to do this? Who knows, there are certain circumstances that are very vague as to why a short seller can be Short Exempt. It just seems those circumstances don't actually matter and are so vague that no one can actually regulate it.
With that said, they have been shorting XXX by the millions by OFF THE EXCHANGE TRADING. Not just by way of short exempt but also regular shorting as well. In addition to that short exempt trading is happening on the exchange too. Yes that's correct, it seems like SSR is a crock of shit as we all have expected.
So look at it like this......
We are getting shorted on the exchange. We are getting shorted off the exchange. We are getting shorted by short exempt on the exchange. We are getting shorted by short exempt off the exchange. I still believe they are doing this OTC Trading for more than just an extra way to short XXX and avoid the SSR rule. Although those are huge I think there is more to it.
So lets take a look at some numbers from FINRA data to see what we have been missing..... I'm also more focused on Short Exempt shares because these are the shares that are not included in any data you are seeing on these finance website & the ones they are trying to hide.
Below is last months total volume of OFF THE EXCHANGE shorting of just 1 TRF (Trade Reporting Facility), and there are multiple TRF's. Notice the Short Exempt Number; 11,551,305.. Those are shares that have shorted avoiding SSR as well as shares that until finding this data is not reported on a website like, say, fintel. 11.5 Million Short Exempt shares we were not counting. That was just last month. We are approaching 30+ million shares they have hidden and we have unaccounted for in our typical "fintel" type data readings to date.
