Comment Text:
10-005
COMMENT
CL-01784
From:
Sent:
To:
Subject:
Robert Redelmeier
Friday, April 9, 2010 9:03 AM
Metals Hearing
Metals position limits
Sir/Madam,
Thank you for requesting comments on position
limits in precious metals futures markets. Mine are:
First, tight (< 1%) position limits are proven firebreaks.
Where large players / market concentration appears desireable
or necessary-to-tolerate, then additional restrictions should
be placed on these entities. Quid-pro-quo. At least augmented
reporting (daily listing of all trades) should be required --
then everyone can see the big players are not abusing their size.
Otherwise, how could anyone know or have confidence?
Second, you have heard and will hear many arguments. By law and
custom, those with the strongest profit interests must defend
those interests with polished argument. Your unenviable charge
is to dissect those arguments and fill-in counterargument for
the absent, profit-shorn American people. Comments help, but I
doubt anything like the equality of a court-room can be expected.
Concentrated interests always outshine diffuse interests.
Third, the CFTC was set up as an _independant_ agency, not
part of the Treasury, Dept of Agriculture, SEC, FRB or any
other body. It was recognized that independence from these
otherwise fine organizations is necessary because sometimes
one or more might need to be dissappointed. Even bitterly so.
-- Robert Redelmeier
2202 Signal Hill Dr
PEARLAND TX 77584
281 544 6209
