I would suggest a through review of the requirements (or lack thereof) for OTC stocks at www.otcbb.com.
Here are some key points:
The OTCBB is a quotation medium for subscribing members, not an issuer listing service, and should not be confused with The NASDAQ Stock MarketSM. OTCBB securities are traded by a community of Market Makers that enter quotes and trade reports through a highly sophisticated, closed computer network, which can be accessed through the NASDAQ Workstation.
The OTCBB is unlike The NASDAQ Stock Market in that it:
does not impose listing standards;
does not provide automated trade executions;
does not maintain relationships with quoted issuers; and
does not have the same obligations for Market Makers.
On some occasions when I've tried to purchase an OTC stock, I have also noticed that my order neither appears, nor fills, despite it's being the best bid. I've also had sell orders where a trade has gone through at a higher price than I offered to sell at.
In checking with my brokerage I was told that because the OTC does not have "market makers" in the sense of the NASDAQ, but rather a listing service to which brokers subscribe, an "OTC market maker" is free to execute any trade with any other "OTC market maker" at any price that the two agree on. They are also not obligated to execute any trade, regardless of a match between bid and asked.
Of course special orders such as "All or None" on occasion do not even show up on the major exchanges and do not have to be shown at all, I believe.
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