Comment Text:
10-005
COMMENT
CL-02593
PIOPADRE
Po Box 710
,Somerset Ohio 43783
LLC
Phone: (614-299-7700)
Fax:
(614-299-9389)
[email protected]
April 22, 2010
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21
st
Street NW
Washington DC 20581
Re: Comment For Position Limits
Dear Sir,
It's amazing how out of line things have become. Because the events have developed over
time, we often lose the proper perspective with which to judge them. How did we get to the
point where much of our markets have developed into pure gambling? Guilt or innocence
aside, the charges against Goldman Sachs depicts a transaction that was a pure bet, with no
economic significance or justification to the economy at large. There was nothing of value to
society. The time has come to crack down on mega bets that involve no economic
justification, especially when those bets are made by government-backed financial
institutions. We need to exercise common sense in rooting out these non-economic games.
No clearer example of the non-economic gambles that need to be terminated exists than in
the silver market. In COMEX silver, there exists the preposterous situation of a major US
bank, JPMorgan, holding a concentrated short position of 150 million ounces. JPMorgan has10-005
COMMENT
CL-02593
held this short position since it acquired Bear Stearns, more than two years ago. It serves no
useful value to society, except to artificially depress the price of silver. In many ways, this
silver short position is much worse than whatever Goldman Sachs is alleged to have done. For
one thing, Goldman wasn't alleged to have manipulated the market. By its very existence,
JPMorgan's silver short position, due to its concentrated nature, can't help but manipulate the
price of silver. The proof of the manipulation lies in the fact that it can't be closed out without
greatly impacting the silver price. Such a concentrated position exists in no other major
market. Further proof lies in the fact that the neither the CFTC, nor JPMorgan, can address the
.
issue directly
,
in spite of a year and a half of formal investigation,
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.
Robert Muetzel
General Partner, Piopadre LLC
