On September 28th, the U.S. District Court for the District of Columbia vacated and remanded the CFTC's position limits for derivatives on 28 physical commodity contracts. The Court found that the Dodd-Frank Act's amendment of the Commodity Exchange Act ("CEA") is ambiguous as to whether the CFTC is required to find that position limits are necessary and appropriate prior to imposing them. Because the position limits rule is based on the CFTC's erroneous conclusion that the CEA is unambiguous on this issue, the rule must be remanded for further agency consideration. ISDA v. CFTC. On October 1st, Reuters discussed Congress' and the CFTC's possible responses to the ruling. Response.