Comment Text:
DEAR CHAIRMAN GENSLER AND FELLOW COMMISSIONERS,
I URGE YOU TO APPROVE THE STAFF'S PROPOSAL ON POSITION LIMITS.
INCLUDING LIMITING EXEMPTIONS TO BONA FIDE HEDGERS. I WOULD ASK YOU, HOWEVER, TO
READJUST THE PROPOSED FORMULA IN SILVER. THE CURRENT FORMULA RESULTS IN A
POSITION LIMIT OF OVER 5,000 CONTRACTS FOR ANY SINGLE SPECULATOR, ON AN ALL
MONTHS COMBINED COMBINED BASIS. 5000 THOUSAND CONTRACTS IS THE EQUIVALENT OF
25 MILLION OUNCES OF SILVER.
IN AS MUCH AS 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 99% OF THE WORLDS 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.
KINDLY INSTITUTE A 1500 CONTRACT (7.5 MILLION OUNCE) POSITION LIMIT FOR SILVER.
RESPECFULLY,
SIDNEY H. KOSANN
