When pink sheet ADRs are traded, the spread can climb into the couble digits. A fully loaded spread is when the market maker piles on fees to make more money. If they are truly larcenous, they will also subtract these amounts from the bid price. Fully loaded spreads occur with narrowly traded ADRs from countries with market or exchange rate volatility. These are created by brokers in response to demand for foreign securities.
Any depositary can create unsponsored ADRs.
The SEC requires that they be fungible, that any unsponsored ADR under a cusip number be equivalent to any other, so that clearing and settlement can work. As a result, the fee structure for unsponsored ADRs is set by the demands of the most avaricious depositary. Investors in unsponsored ADRs may be charged for foreign exchange transactions, right issues or sales, withholding tax, and other transactions, often at an excessive levels. Hidden charges on dividends may include an artificially bad exchange rate as well as fees. Withholding Tax Charged by many countries on dividends or interest paid to owners of ADRs.