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Comment for Proposed Rule 76 FR 4752

  • From: Kevin J. Pantera
    Organization(s):
    United States Citizen
    Retired State Banking Regulator
    Physical Silver Holder and Silver Stock Holder

    Comment No: 28191
    Date: 2/23/2011

    Comment Text:

    RE: Final Position limits on Silver Contracts

    Dear Commissioners:

    You as a regulatory body have the opportunity to formulate a fair and open marketplace for the trading of silver contracts. Currently, their strongly appears to be an unfair advantage strong naked shorting positions being taken in the marketplace; these cause uneven and disruptive gyrations in what should be a fair and open marketplace. These strongly appear to be caused primarily from a small group of institutions that act in a manner that when in collusion with others form strong barriers to open and free trading in the marketplace. The current leverage of 5,000 contracts is far to many for the current amount of silver production in the world on a per annum basis or above ground physical silver. Also, the total amount of these short position contracts cause large imbalances in the silver market, and can cause a panic market in a world where chaos appears to be running rampant. A free flow of buyers and sellers in any fair and honest marketplace is what is warranted. The 1500 amount of contract limits appears to be an amount that would make the silver Comex an even playing field for all concerned, and discourage any wild naked shorting of contracts that niether is sustainable in the spirit of an acceptable and open free and fair marketplace; and if left unchecked gives the naked short positions further unfair leverage advantage and financial power in the marketplace which left unchecked could destroy the exchange or bankrupt the institutions they represent (e. a Berrings Bank situation. You as a regulatory body should be able to see these glaring imbalances and need to fix the problem by allowing no more than 1,500 contracts in Silver.

    Respectfully submitted,



    Kevin John Pantera
    Physical Silver holder,Silver Stockholder and United States Citizen

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