Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. But consider a readjustment of the the proposed formula for silver. The current formula would result in a position limit of over 5,000 contracts for any single speculator, on an all-months-combined basis. 5,000 contracts is the equivalent of 25 million ounces of silver. This is too high of a threshold; silver is a very thinly traded commodity and is considered by laymenr and investors alike as a companion to gold, in that both metals were part of our coinage until the 1970s! Silver is not just another industrial metal..
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 institute a 1500 contract (7.5 million ounce) position limit for silver. That would bring it more in line with other commodities and oblige those who deliberately are manipulating silver spot prices to their own advantage to the detriment of all others.
Yours respectfully,
Douglas Henninger, Richmond VA
