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Comment for Proposed Rule 76 FR 4752

  • From: John Clark Venable
    Organization(s):
    None

    Comment No: 28325
    Date: 2/23/2011

    Comment Text:

    Dear Chairman Gensler and fellow Commissioners,

    I believe you're on the right track with position limits in silver and urge you to approve the staff's proposal. It seems to me, however, that setting the position limit at 5,000 contracts is a very high threshold amounting to 25 million ounces of silver. The United States produces 39.8 million ounces of silver per year (2009 number). The 5,000 contract position limit in silver would be vastly greater than is allowed in other metals or commodities on a proportional basis and I have seen no explanation of why this special treatment is needed to create a fair market for silver futures. I can think of lots of reasons why the hedgies would want it, but that's not who you work for, is it?

    I believe a 1500 contract (or 7.5 million ounce) speculative position limit would limit the ability of speculators to control the price of silver via a concentrated short position.

    Thank you for reading.

    Respectfully submitted,

    Clark Venable

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