Since the Pink Sheets does not accept pre-market or after hours trades, any stocks traded exclusively on Pink Sheets that contain the "T" indicator on a trade, is a trade that did not meet the NASD 90-second posting rule as per above. If the "T" trade appears at the beginning of the day it is because it wasn't posted at Pink Sheets before 5:00 PM on the preceding day.
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. Then we have trades later than 90 seconds after closing. These trades fall into two categories and typically involve larger size lots.
a. The first category 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 are typically used by larger investors to buy larger lots at prearranged prices without risk of driving the price upward or downward.
b. The second category involves so called “ex-clearing” lots. Certain transactions may clear and settle outside of the regular clearing system ("ex-clearing" transactions), where two dealers make an arrangement to settle trades between them outside the clearing system.
The process used to balance street side transactions depends on the type of comparison generated and the settlement method for the particular trade.
Trades Comparison is accomplished in one of two ways:
1. Electronically through the use of an automated clearing house such as the NSCC. This the normal way
2. Manually via Ex-Clearing. Ex-Clearing is a manual comparison process that is performed by the brokerage firm’s Purchase and Sales Department. Unusual short coverings can end up settle this way
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