Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I urge you to approve staff's proposal on position limits, including limiting exemptions to bona fide hedgers. I ask that you readjust the proposed formula for silver. The current formula would result in a position limit of over 5000 contracts for any single speculator, on an all-months-combined basis. 5000 contracts is the equivalent of 25 million ounces of silver. This is too high 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 the same number of industrial consumers using more than that amount. Any speculator holding and 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 position limits is to prevent such a circumstance.
Please institute a 1500 contract (7.5 million ounces) position limit for silver.
Thank you for your consideration.
Very truly yours,
Robert M. Facciola
