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. I would ask you, however, to readjust the proposed formula in 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 in light of the realities of the world silver market.
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.
The silver futures market is losing all credibility in the eyes of investors and has almost become a laughingstock. The CFTC lack of action in light of direct evidence of silver manipulation presented to them in March 2010 makes them fully accountable for standing idly by while manipulative practices take place in the silver futures market at the Comex.
Please institute a 1500 contract (7.5 million ounce) position limit for silver.
In addition, make a public announcement of the silver investigation you promised to the public.
Respectfully submitted,
Richard White
Plano, Texas
