Comment Text:
10-005
COMMENT
CL-00290
From:
Sent:
To:
Subject:
Phil Inj e Chang
Saturday, April 24, 2010 11:05 AM
Metals Hearing
Commentary
Dear CFTC,
Thank you for the public commentary period on position limits and concentration of trading positions in
gold and silver.
In futures markets the original intention of allowing businesses to hedge has become cloudy beyond
recognition in gold and especially in silver. A simple speculative position limit would be a start and then
strictly identifying hedgers and restricting any exemption from the position limit to legitimate hedgers
only is an obvious solution.
Enforcing that will of course require a process of confirming business identities and intentions, and then
monitoring violations with harsh consequences for repeated violations. This undoubtedly will expand
the work you do, and there is always the possibility of circumvention through devious means, but a
harsh penalty will go a long way toward reducing the illegitimate activity currently in plain sight.
Among speculative traders, the COMEX name has been tainted by the questionable activity of a small
number of banks. Establishing clear rules as discussed above will go a long way toward separating the
COMEX name from the manipulative activities of a few participants.
Thank you.
Best regards,
Phil Chang
Phil Inj e Chang
+81 (0)80 3592 0961 (Japan)
philinj [email protected] p (mobile)
philinj [email protected] (personal)
Skype: philinj e
