Comment Text:
Dear Chairman Gensler and Fellow Commissioners:
The current formula used for position limits allows for over 5,000 contracts for any single speculator., on an all-months-combined basis. This is the equivalent of 25 million ounces of silver, which is absolutely too high. The fact is, any speculator holding an amount of silver derivatives greater than the amount that 99% of the world's silver producers and consumers produces of uses in a year will have pricing power that, simply put, will control the market. It should be noted that the intent of speculative position limits is to PREVENT such a circumstance from occurring.
Your staff's proposed limits includes bona fide hedgers, and should be approved. However, the proposed formula for silver should be adjusted to a limit of no more than 1500 contracts. This would still amount to 7.5 million ounces.
The present system gives an unfair advantage to the largest players and as a result, there can be no doubt in anyone's mind that they are definitely having a negative impact on prices w/ respect to the unreasonable size of their positions.
Respectfully submitted,
Steven Smith
