Comment Text:
Dear Chairman Gensler and fellow Commissioners:
Thank for the opportunity to comment on the issue of position limits for precious metals and specifically, silver.
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 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 too high of a threshold in light of the realities of the world silver market.
A 1500 contract position limit (with exemptions to bona fide hedgers only) for silver would guarantee that a single speculator or speculator's working in concert could not gain a large enough share of the silver market to manipulate the price in either direction.
So I ask you to please institute a 1500 contract position limit for silver.
Thanks for your time,
Leo Hirsch
