IATP comment on the revision of the European Commission Market Abuse Directive (MAD) to extend the authority of the MAD to cover Over the Counter (OTC) trades and trades on unregulated venues. Given the volume, value and volatility of OTC trades ($300 trillion in notional value for U.S. markets alone in 2008 according to the Bank of International Settlements), it would be very difficult, if not impossible, to detect market abuse unless MAD were applied to OTC trades. During the past decade, U.S. regulatory exemptions for OTC swaps and failure to enforce position limits were major drivers in excessive speculation.