1jk1,
Any trade that has not been "cleared" where the MM has to get a buy to match the sell is considered a "designated short sale," but it is matched at some point within trading (less the ACTUAL SHORT POSITION, which is found on the OTCBB.com site, and is always FAR less).
Hence, if a trade is "started" by an MM with the "sell" portion (aka short portion) first, and is completed the following morning (well within the FTD period), it will still show up on the "report" as a "short" sale, as all that is is a SUM of the trades considered technically to be "short sales."
Great try, though.
IMO/FWIW