Comment Text:
Dear Chairman Gensler and fellow Commissioners:
Please approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. Please also readjust the proposed formula in silver. The current formula would result in a position limit of over 5,000 contracts for any single speculator on an all-months-combined basis. That is the equivalent of 25 million ounces of silver. It would be too high of a threshold in relation to 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 only a few industrial consumers using more than that amount. Any speculator holding an amount of silver derivatives greater than what almost all of the world’s silver producers and consumers make or use in a year would have excessive pricing power. The purpose of speculative position limits is to prevent such a situation.
Please institute a 1500 contract (7.5 million ounce) position limit for silver.
Sincerely Yours,
David J. Dunak
