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Thursday, 04/10/2008 11:46:37 PM

Thursday, April 10, 2008 11:46:37 PM

Post# of 29782
FYI, Form T late reports

First of let’s all agree, that there is no such thing as an PinkSheet aftermarket.

There are three types of late reports

1. Those with a time stamp within a minute and a half after closing are just normal 90 second delays

Rule 6620.1 OTC Market Makers shall, within 90 seconds after execution, transmit through ACT last sale reports of transactions in OTC Equity Securities executed during normal market hours.

In this case the market makers may have conducted a trade within seconds of closing, but is delayed in reporting until after closing it is showing up a minute after closing. This delay, which is permitted, is often misconstrued as manipulation.


2. And then we have those later than 90 seconds after closing. These trades fall into two categories and typically involve larger size lots

This is sometimes used by financial institutions that are non market makers to report larger transactions that actually occurred during market hours, but since they do not have access to the ACT (Automated Confirmation Transaction Service) use Form T to report. In essence, bypassing the MMs.

MMs are basically prohibited from these "Off Market transaction" as spelled out in

A pattern or practice of late reporting without exceptional circumstances may be considered conduct inconsistent with high standards of commercial honor and just and equitable principles of trade, in violation of Rule 2110.

These ”Off Market” trades is typically used by larger investors to buy larger lots at prearranged prices without risking to drive the price upward or downward.



3. And then for the most popular of all. Reg D 504 selling

Typically, the chosen MM is allowed to sell a certain amount of shares per day based on volume and agreement with the accredited seller. At the end of the day the accounting is squared up and will show as AH informational trades that appear typically between 16:05 and 16:25. They will always be large blocks but typically never larger than 9,999,999. These shares were actually bought by the MM's at the price you see AH. The shares could have been sold at any price.

There are some variations to this but that is the general way it flows. You will also see these large AH blocks on stocks that are using other forms of dilution.

These are shares added to the O/S. This will happen until the dilution has ended and the 504 is satisfied.




See for instance http://www.brokerage101.com/ for further education





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