Comment Text:
Dear Chairman Gensler and fellow Commissioners:
As a consequence of the obvious ongoing manipulation of the bullion markets, I urge you to adopt the proposal on position limits, including limiting exemptions to bona fide hedgers. I would also ask you, however, to alter the proposed formula for Ag. The current formula would result in a position limit of over 5,000 contracts for any single speculator, on an all-months-combined basis. 5,000 contracts is the equivalent of 25 million ounces of silver. This is a ridiculously high 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 only a similar number of industrial consumers using more than that amount. It is absurd to allow speculation on derivatives on this scale. Any one holding holding a position in silver derivatives greater than 99% of the annual production and consumption of the world's silver has inordinate pricing power. This should be illegal.
Only a maximum of 1500 contracts (7.5 million ounce) should even be considered
