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, you need 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 few industrial consumers use 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 with no exemptions.
The CFTC won't be able to sweep the decades long manipulation of silver and gold prices under the rug anymore. This issue is on too many people's radar screens now. Whistleblower Andrew Maguire's public testimony and Ted Butler's painstaking research has highlighted the CFTC's regulatory failures for all the world to see. The CFTC's multi year ongoing "investigation" looks like a coverup. How many years does it take to look at your own public data and see how silver (and to a slightly lesser extent gold) are the only commodities markets on the planet that are completely dominated and controlled by 1 to 2 commercial traders? There can be no legitimate purpose for the "4 or less" commercial traders (bullion banks) obscenely huge net short positions in silver and gold. It is time to end this ongoing fraud now before it blows up in a market failure.
Sincerely,
Todd Schongalla
