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.
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. 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.
Due to the blatant manipulation of the metals markets for over 10 years, and the apparent un-adjudicated and seemingly encouraged state of criminality within the stock markets in the US, I have pulled all my investments from the market and I am waiting for some overdue criminal prosecution from the justice department to rein in the criminality in the stock markets. I cannot believe that the SEC and CFTC would allow and seemingly sanction this behavior. But since there has been no evidence of reining in these abuses, the abuses appear to be sanctioned by these regulators, by lack of active regulation on their part.
Respectfully submitted,
Rick Solinsky
