Comment Text:
Dear Chairman Gensler and Commissioners:
I urge you to approve your staff’s proposal on position limits, including limiting exemptions to all hedgers. I would ask you to adjust the proposed formula in silver. The current formula would result in a position limit of over 5,000 contracts (25 million ounces) for any single speculator, on an all-months-combined basis. Only three mining companies world wide produce over 25 million ounces of silver annually, and there are few consumers of such a large amount.
A limit of 1500 contracts (7.5 million ounces) for silver is far more appropriate, I believe.
Particularly egregious is the practice of exemptions to position limits, especially when granted to large banks. Banks neither produce nor consume silver, and so are speculators in silver for whom exemptions are inappropriate. You have surely noticed the rise in silver's price, which means these banks, or their customers, have lost large amounts of money, which I suspect will lead to another expected bailout from us taxpayers. Had there been a position limit of 1500 contracts, a bailout would be far less likely for banks, miners, industrial consumers, or speculators. There should be no exemptions to position limits for any reason.
I strongly urge you to institute a 1500 contract (7.5 million ounce) position limit for silver, with no exemptions.
Respectfully submitted,
William B. Houseman
