Comment Text:
Silver Position Limits.
There are 4 commodities with position limits greater than 1% of world production. Cocoa at 2%, Coffee 1.5%, FCOJ 1.25% and Silver the outlier at 4.3%, it is my view that silver be brought in-line with other commodities.
I haven’t seen any logic presented by the CFTC on how this 4.3% was reached. It is because of the untiring efforts of commissioner Chilton alone that I have taken the time to offer the following suggestion.
Based on current silver world production (WP) at 700Moz and 5000oz/contract I suggest silver position limits be less than 1% of WP or 1400 contracts either long or short.
It is my view that exemptions should be granted to bona-fide hedgers. Exemptions should be granted by organisations that are not conflicted, ultimately by the CFTC.
Furthermore the public has been waiting patiently for over 2 years (a record) for the conclusion to the current silver investigation. I urge the CFTC to update the public.
