SIFMA and the International Swaps and Derivatives Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on a Notice of Proposed Rulemaking relating to position limits for derivatives, RIN 3038-AD15 and 3038-AD16.  The proposal would impose speculative position limits on futures and option contracts in 28 exempt and agricultural commodities and their economically equivalent swaps in order to implement Section 737 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).  The groups are deeply concerned with many aspects of the proposal and challenge the fundamental premise upon which the CFTC argues that it has authority to impose position limits under the Dodd-Frank Act.