General Comments The CFTC has argued that the Dodd-Frank legislation mandated that it establish speculative position limits for all exchange-traded commodities including energy products, metals, soft commodities and others, with exemptions for legitimate hedging and risk management functions. It proposed and ultimately approved regulations accordingly. However, as you may recall, about a year ago the regulations were thrown out by a federal district court based on a challenge from a couple of trade associations. The challenge contended that CFTC had not justified or demonstrated the need for position limits. CFTC argued that since the law mandated position limits, it did not need to submit justification for them. The court ruled agains...