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Comment for Proposed Rule 76 FR 4752

  • From: Raymond j McGowan
    Organization(s):

    Comment No: 29529
    Date: 2/25/2011

    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.

    Please institute a 1500 contract (7.5 million ounce) position limit for silver.

    Very truly yours,

    R. James McGowan
    Attorney at Law
    3865 Yellow Creek W.
    Akron, Ohio 44333

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