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Comment for Proposed Rule 76 FR 4752

  • From: Lloyd R Pennell
    Organization(s):
    American

    Comment No: 33320
    Date: 3/27/2011

    Comment Text:

    "The core issue is that there exists an unusual concentration on the short side of COMEX silver futures held by JPMorgan. Manipulation can only exist if a concentrated position exists. Everything else is a peripheral matter. It does not matter if the concentrated silver short position held by JPMorgan is naked or is hedged with physical or OTC offsets. It does not matter if JPMorgan inherited the concentrated short position from Bear Stearns at the request of the US Government. It does not matter if JPMorgan operates an exchange -- licensed or not. What does matter is the concentrated nature of its COMEX silver short position [in the futures market]."

    "What also matters is that the only known antidote to concentration isthe enactment of legitimate speculative position limits, something now lacking in COMEX silver futures. That’s why the current position limit process underway by the CFTC, including the solicitation of publiccomments on the matter, is so important. Fortunately, there has been an outpouring of public response on this issue with well over 3,000 comments being made by fellow citizens and investors asking that the Commission institute a 1,500 contract position limit in silver. I am hopeful that the large number of comments on silver will finally result, at a bare minimum, in an open discussion by the CFTC onthe merits of a 1,500 contract level in silver. For more than 20 years, any thought of an open debate has been buried."

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