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1 See Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111–203, 124 Stat. 1376 (2010). The text of the Dodd-Frank Act may be accessed at http://www.cftc.gov/Law Regulation/OTCDERIVATIVES/index.htm. 2 Pursuant to Section 701 of the Dodd-Frank Act, Title VII may be cited as the ‘‘Wall Street Transparency and Accountability Act of 2010.’’ 3 7 U.S.C. 1 et seq. 4 Section 1a(20) of the CEA defines the term ‘‘exempt commodity’’ to mean a commodity that is not an excluded or an agricultural commodity. 7 U.S.C. 1a(20). Section 1a(19) defines the term ‘‘excluded commodity’’ to mean, among other things, an interest rate, exchange rate, currency, credit risk or measure, debt or equity instrument, measure of inflation, or other macroeconomic index or measure. 7 U.S.C. 1a(19). Although the CEA does not specifically define the term ‘‘agricultural commodity,’’ section 1a(9) of the CEA, 7 U.S.C. 1a(9), enumerates a non-exclusive list of agricultural commodities, and the Commission recently added section 1.3(zz) to the Commission’s regulations defining the term ‘‘agricultural commodity.’’ See 76 FR 41048, Jul. 13, 2011. 5 See Position Limits for Derivatives, 76 FR 4752, 4753 Jan. 26, 2011. Specifically, the Commission proposed to withdraw its part 150 regulations, which set out the current position limit and aggregation policies, and replace them with new part 151 regulations. 6 See e.g., Letter from Professor Greenberger, University of Maryland School of Law on March 28, 2011 (‘‘CL–Prof. Greenberger’’) at 6–7; and Petroleum Marketers Association of America (‘‘PMAA’’) and New England Fuel Institute (‘‘NEFI’’) on March 28, 2011 (‘‘CL–PMAA/NEFI’’) at 5. Also, over 6,000 comment letters urged the Commission to ‘‘act quickly’’ to adopt position limits. COMMODITY FUTURES TRADING COMMISSION