Comment Text:
February 25, 2011
Dear Chairman Gensler and fellow Commissioners:
I have been following the position limit issue for quite some time. I want to urge you to act on this issue firmly as I believe a position limit of 5,000 contracts as has been suggested is entirely too high. 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. I understand that there are numerous proponents of the 1500 contract limit, and I urge the commission to listen to the public voice and implement position limits at this level.
Best Regards,
Rob Mabary
