Just noticed that Zecco now accepts orders on OTC PINK reporting stocks (that is, the tier below OTCQB that reports to otcmarkets.com instead of the SEC) even if the order size exceeds 10%-20 day ADV.
At least that's what I got by placing a dummy buy order for YGDC at a price far below bid, with no intention of getting it executed at all.
BTW eTrade for example doesn't even charge non-DTC eligible fees, they figured out that the customer isn't the one who has to know how a trade is cleared; couple that with $9,95 per-trade fees acting as insurance against extreme low-probability exceptional cases and the fact most penny stock trades are cleared thru them, and that pretty much explains why there aren't certificate fees...since shares are held in street name, I guess non-DTC trades are cleared by simply changing ownership from eTrade (mention to account A) to eTrade (mention to account B).