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Comment for Proposed Rule 76 FR 4752

  • From: John Coffey
    Organization(s):

    Comment No: 28357
    Date: 2/23/2011

    Comment Text:


    Dear Chairman Gensler and fellow Commissioners:

    I very strongly urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. And I commend you for requiring to see the swap books behind the trades of all short sellers beyond those limits. I personally believe that it is highly likely that the swap books contain the name of a known enemy of the United States, and that many of the trades are designed to undermine the national security of the United States.

    But, I would ask you to readjust the proposed formula in silver. As you know, the current formula would result in a position limit of over 5,000 contracts for any single speculator on an all-months-combined basis which 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. I believe that 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.

    Additionally, if the Commission allows the will of the big banking interests, domestic & foreign, over the combined will of the American public, I believe that it will lead to a silver shortage, endangering the national security of the United States. The USA has NO strategic silver reserves, a strategic industrial metal critically necessary for our economy and our military. Also, I believe that China is currently stockpiling all the silver (and gold) reserves it can purchase at artificially low prices, which they themselves may have a hand in creating through the abuse of the current lack of legitimate position limits.

    Respectfully submitted,

    John Coffey

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