Comment Text:
10-005
COMMENT
CL-01238
From:
Sent:
To:
Subject:
ROBERT LAMB OURNE
Saturday, April 10, 2010 10:59 AM
Metals Hearing
Position limits
Dear Sirs,
I am a private investor based in the UK who has regularly invested in both gold and silver and related
futures contracts. I have followed with interest your recent hearings on precious metals and especially
the debate about position limits. May I thank you for the opportunity to comment on this issue. I am,
like many other private investors, concerned about the way the silver market is being managed and on
the face of it there seems to be a concentration of positions in COMEX silver by commercial shorts
which seems unhealthy.
Hence, I consider that there is a need to establish a speculative position limit in COMEX silver of no
more than, say, 1500 contracts which is a limit which has been suggested to you be a number of
commentators. I think the limits in silver should bear comparison with the limits established for other
COMEX markets, such as for energy markets. Please restrict any hedging exemptions from those limits
to legitimate hedgers with appropriate evidence being made available to you to establish that they are
indeed legitimate hedgers.
Last, but not least I urge you to act to reduce the levels of concentration in COMEX silver futures that
have been experienced over the past few years on the short side of the market.
Yours faithfully,
R. E. Lambourne
