Comment Text:
10-005
COMMENT
CL-00204
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Sent:
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Subject:
Lee Knoper
Saturday, April
24,
2010 5:44 PM
Metals Hearing
[Feedback] Metals position limits
Secretary, Commodity Futures Trading Commission:
I'm inclined to strongly agree with silver analyst Ted Butler
that something is seriously wrong in the COMEX silver market
because of the level of shorts and the concentration in the
hands of so few participants. Even if Butler is wrong and
all the "curious developments" are merely normal, innocent
market actions, the inability or unwillingness of CFTC to
address the complaints plays right into the hands of
conspiracy theorists, and this itself is hardly conducive to
a properly functioning market. Markets must be responsive
to query and transparent in operation. This one isn't.
I strongly favor a speculative position limit of 1500
contracts in COMEX silver. Hedging exemptions should be
restricted to legitimate hedgers. (I do not consider the
bullion banks to be legitimate hedgers.) The levels of
concentration of short positions in COMEX silver futures
must be sharply reduced and more closely monitored.
Lee Knoper
Tucson, AZ