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Comment for Sunshine Act Sunshine Act Meeting: March 25, 2010

  • From: Carl Royer
    Organization(s):

    Comment No: 21217
    Date: 4/11/2010

    Comment Text:

    10-005
    COMMENT
    CL-00918
    From:
    Sent:
    To:
    Subject:
    Carl Royer
    Sunday, April 11, 2010 4:30 PM
    Metals Hearing
    comment on issue of position limits for precious metals
    Dear Sir;
    It has been suggested that I write to you in a form somewhat like this:
    "Thank for the opportunity to comment on the issue of position limits for precious metals. Please
    establish a speculative position limit in COMEX silver of no more than 1500 contracts. Please
    restrict any hedging exemptions from those limits to legitimate hedgers. Please stop the levels of
    concentration in COMEX silver futures that have been experienced over the past few years on the
    short side of the market."
    I'm not convinced that limits would be the answer. There is probably truth in the retort that the
    shorts would move to a different venue such as London, and we would no longer get the action due
    to over-regulation. Maybe that would solve the problem, maybe not. Who really knows?
    What Iam suggesting is transparency. I believe in open markets in all senses of the word. Tell us
    'who has what position and how many and how much' on a delayed basis such as 24 or even 48
    hours, so we can decide for ourselves whether markets are being manipulated and by who.
    Sincerely,
    Carl Royer