They are...in fact I remember a few years ago I requested that they allow purchase of a particular OTC stock and they said they wont allow it because it was not DTC eligible or registered with the SEC. At the time I didnt understand what that meant and found that it was easy to use Etrade to purchase the stock. Foolishly I admit, it was a hard lesson learned.

Later i learned thru an audit of said stock that there position size was one of the least on a NOBO and OBO list. Which made me ask how did they get the position in the first place? Then I thought about physical stock certificate and how trades can be made not thru a discount broker or online.