Comment Text:
From the CFTC’s web page: “The CFTC's mission is to protect market users and the public from fraud, manipulation, and abusive practices related to the sale of commodity and financial futures and options, and to foster open, competitive, and financially sound futures and option markets.” In the supposedly new era of transparency and regulation, the commission’s proposed rules on position limits fall far short of such. I will comment on a couple of the more egregious rules set forth.
1. Spot-month position limit levels set at 25% of deliverable supply for a given commodity, with a conditional spot month limit of five times that amount for entities with positions exclusively in cash-settled contracts –-- Say what? I would understand the rule to mean that the big investment banks could take a position of 125% of deliverable supply in the spot month. It looks like its business as usual as far as concentrated positions in silver futures for example. How does the small retail investor stand a chance when positioned against an entity that has the means to take full advantage of this proposed rule?
2. Exemptions for bona fide hedging transactions and for positions that are established in good faith prior to the effective date of specific limits adopted pursuant to the proposed regulations. ----- Again, business as usual and the big boys win again. Got to keep those big bonuses up there where we can see them. The SEC couldn’t handle Madoff and it appears the CFTC can’t handle the big special interests.
To:
Gary Gensler: What have you learned from Brooksley Born’s tenure as chairperson of the CFTC?
Scott O’Malia: I feel the need to hit the mute button.
Jill Sommers: Always needs more analysis and study. Probably feels the same way on the continuing silver investigation that is now approaching three years.
Bart Chilton: Finally a public official that speaks plainly and to the heart of matters before him. Keep up the good fight.
