General Comments When a federal judge threw out CFTC's arduously constructed new regulations setting position limits for commodity futures markets on 28 September -- about two weeks before the regulations were to go into effect -- the action obviously surprised CFTC's commissioners and staff. The judge faulted CFTC for assuming that Congress mandated position limits under Dodd-Frank, and for not demonstrating that position limits are necessary to diminish or eliminate excessive speculation as the precise language of the legislation requires. He handed the matter back to CFTC for further consideration. Now the commissioners appear on the verge of deciding to appeal the court's decision. A decision by CFTC to appeal is expected shortly. Me...