Comment Text:
10-005
COMMENT
CL-02574
Sent By: Real Estate Advzsory Set'vices, ; 503-243-7915;
Apt-24-10 13:42;
Page 1/2
From: Kerry Bates
Subject= COMEX 8tlv~- Politlon Llmft~
Date:
April 24, 2Q10 11:50:19 AM PDT
To: metaisheadng @cftc,gov
De~r
Sirs;
Thank for the opportuni~ to comment on the issue of position limits for precious metals. Please establish a speculative
position limit ia 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 tt~e
past few years on the short ~ide of the market.
The true distortion of these mad~ets is causeA by certain large banks which claim ~ be hedgers (-and seek exemptions) so
they don't have to abide by these limits. Thc~ i~titut'ions can overwhelm markets with fl~eir outsized positions and move
tho price ~o whatever level g~nerat~s a profit for them. In the past, two banks hav~ held 99% of Lhc net short position in
silvt,'t, a clear manipulation.
The LBMA members/dealers ~u~e truing the US markets, th.e Comex and SLV (E'IT), to manipulate and commit fraud
against its own customer.
HSBC and JPMorgan Chase a_re market makers on the LBMA. Together they own 95 percent of the over-the-counter
precious metals derivatives as reported to the U,S. Office of the Comptroller of the Currency, and, by comparison with the
CFTC Bank Participation Report, HSBC m~d YPMorgan Chase are the biggest short sellers on the Come×.
Since the LBMA is not really buying all the metal that inw..~tors are supposedly pttrchasing &om it in unalloeated
acc, otmts, not only is the LBMA hurting those inveslors but it is
also
suppressing the exehange price of the bullion held in
allocated accounts for tkeir customers,
Where is the warning to owr~er~ of allocated metal acczuats that their trtfllion dealer is rurming a scheme that involves
deliberately and willl~dly selling naked short, against their investment?
Goldman Sachs has just been eb~urged with fraud for failing to advise customers to whom they were .~lling a particular
inv~.~-tment that tl-~ firm l~ad been paid by the John P.auLsoa Fund to engineer the tnve.~Tnent in a way that made it l~ely to
go down in price.
There is an exact parallel, in selling allocated gold as a safe tmven i~vestment mad failing to disclose that activities of
same bank will impede its price from rising or even make its price go down,
The bankdmanagers are trading against
its own
client_~investors without diaclosttre.
The CFTC hearing in Washington was about safeguards against, and limits on, naked ~ort selling at the Comex. The crux
of the .~candal is that the banks have been ~elling what they do not have in order to manipulale the
price trod
&eat
invegtors (and actual miner~).
Naked short selling ill size is a ¢al~cer in the fina~acial m'arkots, And the way in which the Banks are obstinately fighting
agair~st any and al! reforms that atmmpt tO limit naked short selling shows tt~e objective observer ttmt they are firmly
committed to a statu_~ quo that is designed to distort the markets and the real economy for their short term advantage,
Lefs be clear about this: naked skort ~!ling in size is not a trading strategy, it Is a mea~s to a fraud.10-005
COMMENT
CL-02574
Sent By: Real Estate Advisocy Sem/ices~ ; 503-243-7915;
Ap¢-24-10 13:43;
Page 2/2
It is f'a.scir~ating, the US Government is c~ltng China a currency market manipulator. Why. doesn't the US take the log
jams out of i~ own eyes befbre it asks other nations to re,hove flae ~plinters from .their?
Since the CFTC hearing on gold and silver irt March, the "market" pri.oe action in gold and silver conttr~ues as if'the
bullion banks, led by JPM and HSBC, .are. laughing at any potential CizI'C actio~ to stop their m~sive concentration and
manipulation of the gold and silver market.
CFTC Commissioners:
'l'he fact.~ are out there. Will anylhing be dor~ about it'? Will these few banks be
allowed to continue to make a mt~kery of the CFTC and US markets? The banks havolved in this market manipulation
are financial ~errorist.~. What is the CF'I'C going to do about it?
Sincerely,
Kzrt-y Bates.