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Comment for Proposed Rule 76 FR 4752

  • From: David E Bruce
    Organization(s):

    Comment No: 33284
    Date: 3/27/2011

    Comment Text:

    The CFTC should immediately impose the 10 percent threshold on position limits the commission has proposed to comply with Dodd-Frank financial reform law. Since that law’s passage last summer, the commodities exchanges have issued waivers permitting the ownership of silver positions above the limits the C.F.T.C. has proposed, and which were supposed to be in place by January of this year. Yet the waivers remain in place, and the big traders have not been penalized. I believe violations to the Commodity Exchange Act have taken place in silver and other markets, and that any such violation of the law in this regard should be prosecuted.

    The Commodities Futures Trading Commission should immediately release the files from its investigation into the supposed manipulation of the silver market so the public can determine whether JPMorganChase and HSBC did anything illegal.

    Certainly, the COMEX and their new owner, the CME Group, continues to look the other way and tries to ignore the growing awareness of a crime in progress. They facilitate the manipulation by continuing to raise the margin requirements, like they did on silver this last week. Obviously other parties knew it was coming before it was announced, as illustrated by the dramatic drop in prices prior to the announcement. They facilitate the manipulation by expediting JP Morgan's vault license to take silver deliveries in the face of public outrage.

    Basically, the commissioners must do the job they are required to do congruent with their mission statement: "to protect market users and the public from fraud, manipulation, and abusive practices related to the sale of commodity and financial futures and options, and to foster open, competitive, and financially sound futures and option markets."

    I appreciate the CFTC providing this forum to receive public commentary, and thank you for all your work on this issue.

    Respectfully, David E. Bruce

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