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. However, I would ask that you readjust the proposed formula in silver. Five thousand contracts is the equivalent of 25 million ounces of silver, and this is too high a threshold in light of the history of the world silver market.
Since this is an amount of silver greater than what 99% of the world’s silver producers and consumers make or use in a year, a speculator holding this much silver would have inordinate pricing power; and since the purpose of speculative position limits is to prevent such a circumstance, only a substantially lower limit, say 1500 contracts or fewer, would have a chance of achieving this effect.
Respectfully submitted,
