Comment Text:
Dear Chairman Gensler and fellow Commissioners:
This comment submission is to request that you approve the staff’s proposal on revision of position limits. However, I specifically request that you readjust the formula which is proposed for silver. The current formula would result in a position limit of over 5,000 contracts for any single speculator. Since 5,000 contracts is the equivalent of 25 million ounces of silver and there are only three mining companies in the world who produce more than 25 million ounces of silver per year, such large limits would make a mockery of the concept of a free and open market. As a relatively small individual investor in silver, I believe such a level totally distorts the market and in effect shuts out the small investor altogether. 5,000 contracts is simply too high of a threshold and is acceptable only to the largest institutions to the total disregard of the small investor. Furthermore, there are only a similar number of industrial consumers using more than 25 million ounces of silver. Thus 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 if not absolute pricing power. The purpose of speculative position limits is to prevent such a circumstance.
I therefore respectfully request that you as the Chairman and your fellow Commissioners whose primary purpose is to create an viable, open and fair market, consider the facts above and that you institute a 1500 contract (7.5 million ounce) position limit for silver. By so doing, you will create a situation which is far more acceptable to most market participants, not just a privileged few of the largest institutions.
Sincerely,
Charles B. Harrison Sr.
