ARCA needs a composite up-tick for listed. ARCA needs a composite plus bid for OTC if routed outside of ARCA. No up-bid needed if both buyer and seller are on ARCA. Only way around is to be short-exempt. e.g. Bona fide hedge or options market maker.
I only trade NASD stocks, and on occassion ETF's.... I've never had a problem..... http://www.directaccesssoftware.com/ Please view features in the lower left hand corner.