Comment Text:
10-005
COMMENT
CL-02788
Ftpr
12 10 11:47a
p.1
KEVIN
R.
JOI-INSON~ GLU,
LIFE AND DISABILITY INSURANCE
SUITE
800
7500 COLLEGE BOULEVARD
OVERLAND PARK, KANSAS 66210
TELEPHONE (913) 661-7246
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Center
1155 21
st
Street NW
Washington, DC 20581
TELECOPIER (913) 661-7297
Sent by Fax: 1-202-418-5521
Re: Metals Trading Position Limits
Dear Sir:
Thank you very much for the opportunity to comment on the issue of position limits in
the trading of precious metals. I am writing to request that you establish a speculative
position limit of no more than 1500 contracts for those trading in silver futures on the
COMEX. I also request that you limit any hedging exemptions from those limits to only
those firms and individuals who are legitimate hedgers and that you do NOT exempt
those investment banks who wish to characterize their investment positions as hedging.
Most importantly, I would ask that you stop the level of concentration in silver futures
positions on the COMEX that have been created over the past many years on the short
side, just as you would on the long side if I were to try and establish such a position. It
has to be manipulative on either side of the market, when one or a very few parties hold
the vast majority of the positions on one side against a much more diversified and
varied group of individuals and firms on the other side. It's the concentration that
creates the manipulation and not the size alone. And it's the concentration that has to
be removed.
Thank you for your courtesy.
KRJ/jrr
