Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. I would ask you, however, to please readjust the proposed formula in silver. The current formula would result in a position limit of over 5,000 contracts for any single speculator, on an all-months-combined basis. 5,000 contracts is the equivalent of 25 million ounces of silver. This is too high of a threshold in light of the realities of the world silver market. It in fact , borders on ridiculous.
There are only three mining companies in the world who produce more than 25 million ounces of silver per year and only a similar number of industrial consumers using more than that amount. Any speculator holding an amount of silver derivatives greater than what 99% of the world’s silver producers and consumers make or use in a year would have inordinate pricing power. The purpose of speculative position limits is to prevent such a circumstance.
Please institute a 1000 contract (5.0 million ounce) position limit for silver. It is time the blatant manipulation in these markets by the big banks and speculators comes to a quick end. Your current rules that are in place represent an un-level playing field and are are most certainly an accident waiting to happen.
Please do what is , RIGHT not what is EASY !
Respectfully submitted,
Robert Nemy
CEO
Nemy International
