Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I urge you to implement a strict 1500 contract (7.5 million ounces) position limit for silver. The current staff proposal would result in a position limit of over 5,000 contracts for any single speculator, on an all-months-combined basis. This limit is the equivalent of 25 million ounces of silver, which is too high 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.
Additionally, I urge you to reject any exemptions to position limits for a so-called "bona fide hedger". The status of "bona fide hedger" is difficult to define and police effectively, and is an invitation to circumvent the purpose of position limits by those who might want to dominate and control the market for silver.
Respectfully submitted,
David Prichard
