Come again, the Market Makers do in fact make a market here in the OTC, when they sell the initial leg open that is in fact making a market for the security. In some cases although a rarity here in the OTC, they have even sold open positions with no cover located on the expectation of an overvalued security tanking within a 3 day period. In one such case this summer that was a costly error for a broker at BKRT, cost him his portfolio and his job due to the massive loss he incurred when he guessed wrong.
However you are correct that the Market Makers here do not carry inventory of these junk securities, they moved away from that years ago. They dont even accept the initial Float any longer as the sponsoring broker dealer, they leave that to the DTCC to take on.
There isnt a "grey" area here, you might have a case on the Exchanges but not here in the OTC, there isnt anywhere to hide.
News 
Market Data 
Discover 
