Nice.. learn something everyday....
http://www.sec.gov/divisions/marketr...
*****Rule 10b-18 does not cover privately negotiated (off-market) repurchases, nor are these shares counted in an issuer's daily volume limitation
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Rule 10b-18 applies to repurchases of OTCBB and Pink Sheet securities. However, OTCBB, and Pink Sheet securities are not reported in the "consolidated system" for purposes of applying Rule 10b-18's price condition (as compared, for example, to Nasdaq SmallCap securities). Bids and last sale prices for OTCBB and Pink Sheet securities are displayed and disseminated on an "inter-dealer quotation system" that displays at least two independent priced quotations for the security. For all other eligible securities, the issuer would need to look to the highest independent bid obtained from three independent dealers (i.e., the "three quote rule").