yes they can as they dont have to file anything in advance of purchasing shares on the open mkt that I am aware of.. USAFA recently brought this up again when KATX purchased shares back in Q1 as reflected on p.8 again there was no mentioning they were doing so ahead of time...fwiw I dont think even the bigboard stocks have to announce buying their own shares on the open mkt. before they do...as for who's selling...take your pick there is long list of MMs very close to this pps on the ask side http://www.otcmarkets.com/otciq/ajax/showFinancialReportById.pdf?id=37337