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

  • From: Nick Laird
    Organization(s):

    Comment No: 22466
    Date: 4/7/2010

    Comment Text:

    10-005
    COMMENT
    CL-02167
    From:
    Sent:
    To:
    Subject:
    Sharefin
    Wednesday, April 7, 2010 10:52 PM
    Metals Hearing
    Position Limits on Gold & Silver
    Dear Sir,
    Please follow-up with what you have been looking into & clear the markets from manipulation by ensuring that market players - be they speculators or
    market makers cannot become Gorillas using Guerilla tactics as has been happening.
    Below are some charts I've drawn from public data that showcase the current lopsidedness in the markets & also show the reasons why changes need to
    be made.
    From all evidence if JPM was pulled back from their bullying position the markets would be much fairer for all.
    Other Banks
    (Mainly
    $2t.2B
    ¢itibank
    $t.2B
    OC, C US Gold & P~ Derivatives
    Notional VaNes Dec 2009
    This data l~resuunedly ~eveus US ."~l;distics
    ~)lll~.
    The Bits lists T~tal W(~I hi GoM & PM derNali~es at
    ~l~ii~ ~WliS llle {ilhel $517 Billieli in Geld & PM
    Source: http://~.occ.treas.gov/ftp/release/2010-33a .pdf
    world gold charts @ ~.sharelynx.com
    !JP Morgan Chase Bank
    Citibank
    Other t000 Banks10-005
    COMMENT
    CL-02167
    IUS OCC Go~d & PM Derivatives
    1
    Billions of Notional Dollars
    [] All Other Banks (Mainly HSBC)
    [aJPM
    Source: OCC
    world gold chars @ www.sharelynx.com
    $160,000
    $140,000
    $120,000
    $100,000
    $80,000
    $60,000
    $40,000
    $20,000
    $010-005
    COMMENT
    CL-02167
    ...................
    JP Morgan Cl ase Bank Gold & PM
    Percentage of Market Share
    Derivatives . .
    world
    gold ch~rts @ www.,harelyn×.¢~m
    Source : OCC
    IO0
    90
    80
    7O
    60
    50
    4O
    30
    20
    10
    0
    As can be clearly seen in the last chart JPM has become the Gorilla in the room with now close to 80% of marketshare.
    Now it becomes clear that with such control, little moves have large effects because now JPM is effectively the market.
    Here is another study showing market manipulation - presumably by the Gorilla
    I spent a few weeks compiling intraday 2 minute tick data and setting it up to process.
    Here's what I got after averaging 4 years worth of data from March 2006 to March 2010
    Laying out each minute - each hour - each day - side by side to show any market manipulation.
    The time on the X scale is GMT so the major slide downhill is occurring between 9-10 AM. (New York is GMT +5 hours.)
    There's also the period at the end of trading when CME is closed but access trading is open.
    So even though gold has risen $550 through this period you can see where they knock it down at the NY open & also at the NY close .
    And it shows the same formation as Dimitri found in his earlier models.
    http://www.miprox.de/Graphiken/Gold Manipulation Intradav Charts.html
    Of interest is the average downturn of the 9-10AM slide over this four years or approx 1000 days (4 x 250 trading days per year)
    Here you can see that it is approx 50 cents (817.7 to 817.2)
    If we are to multiply the 1000 days by 50 cents then one would presume that had this manipulation not happened then gold would be $500 higher.10-005
    COMMENT
    CL-02167
    ...................................................................... [~]traday Gold ~lanipu~atio~] .............................................................
    817.8
    817.7
    817.6
    817.5
    817.4
    817.3
    817.2
    ~
    '
    ttewY~kg-lOam ..... /. .........
    ' ~ ~
    l~l~t nin
    9
    I~lat~ip~tlati~t~
    ..................
    ~
    i,~J
    ............................................................................. ,¥
    ................................................................................................................. 817.1
    ................................................................................................................. 817.8
    816.9
    Hours :- GMT
    1 2 3 4 5 8 7 8 9 10 11 12 13 14 15 18 17 18 19 20 21 22 23
    Please work through the problems to bring a more transparent, honest approach to market players.
    Regards Nick Laird