And yes one would think since he was above 5% he would have needed to file everytime he bought within a few days but I don't see any form4's. The 13G he only needs to file once a year I think.
You for sure have much more experience in these questions then I do and how it works on otc, as long as he have been buying all these shares on the open market I really don't care much about sec-reporting. Though he seems like a thorough guy so that is why I'm a little bit unsure about how he ended up with >5M shares. My guess is that he also have Rochdale shares now, but we'll soon know about that, Rochdale filed 20th of Januarey last year.