Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I am in favor of your approving the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. However, please readjust the proposed formula in silver.
The current formula would result in a position limit of over 5,000 contracts for any one speculator, on an all-months-combined basis. 5,000 contracts is the equivalent of 25 million ounces of silver. This is, in my opinion, too high of a threshold.
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. This would defeat the purpose of position limits. Is not the purpose of speculative position limits to prevent such a circumstance?
Please institute a 1500 contract (7.5 million ounce) position limit for silver.
Thank you for soliciting comments on this most important issue.
