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Comment for Proposed Rule 76 FR 4752

  • From: David I. Gardemann
    Organization(s):
    Self

    Comment No: 28630
    Date: 2/24/2011

    Comment Text:

    Dear Sirs,

    In a few days you will be determining the amount of silver any investor or speculator can hold at any one time in the futures market. The present rules proposed, if I understand them correctly, will allow any one entity to hold 5000 positions and in my opinion that is way to much. Probably the best individual I know that analyzes this market today is Ted Butler and he says that 1500 positions is about right and I agree with that analysis.

    In the past I have been a commodity broker and traded many of the commodities that you control limits on for my own account. I no longer trade as the risks are to high for a retired individual on a fixed income, but I do have several of the physical products presently controlled by the Comex and even though I don't trade, the price I will receive when I decide to sell, will be affected by the commodity markets. Therefore as a man who has some knowledge of how these markets work it is my belief that the limits must be set lower than is presently recommended by the staff if proper price discovery is to be reached.

    In my opinion the proposal presented by Mr. Butler and Mr. Weir in their comments are the right level for the silver market.

    Sincerely,

    David I. Gardemann

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