Comment Text:
The silver market has been manipulated by a concentrated short position. You cannot have manipulation without a concentrated position. The only effective way to prevent concentration is by enacting legitimate speculative position limits.
This now appears to be recognized by the CFTC in their latest position limits proposal.
It is vital however that the limits imposed have a basis in logic and relate to the actual variables of the market and of suppliers
The proposed limit of 5,000 contracts does not do so. 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 therefore institute a 1500 contract (7.5 million ounce) position limit for silver with NO exceptions
