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Comment for Proposed Rule 76 FR 4752

  • From: Timothy A Aiken
    Organization(s):
    PQ Technologies, Inc.

    Comment No: 29216
    Date: 2/25/2011

    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 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.

    Any speculator holding an amount of silver derivatives greater than what 99% of the world’s 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.

    Please institute a 1500 contract (7.5 million ounce) position limit for silver.

    Respectfully submitted,

    Timothy A Aiken

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