Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I have followed the deliberations over position limits in the silver market to my great disgust. From what I understand, your staff has proposed reasonable limits and the public has echoed their approval. However, the commissioners seem to absolutely ignore the comments from the public and the staff. Is this just another part of the “good old boy” system of scratching the backs of your cronies at the big banks? When will the commissioners ever wake up and put some real teeth into silver position limits? The manipulation in this market has and is an on-going crime that the commissioners have turned their backs on. When will it ever stop? Please make a stand for fair position limits in the silver market!
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 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.
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 1500 contract (7.5 million ounce) position limit for silver.
Respectfully submitted,
Tommy Page