Comment Text:
Speculative positions in silver futures markets should be subject to a few simple rules:
1. the rules are the same for shorts and longs
2. the rules are the same for large players and small players
3. the rules do not favor consumers over producers, or vice versa.
4. position limits for each player are defined not as a number of ounces, but as a percentage of the previous year's world-wide production of the commodity.
5. naked shorting is criminally fraudulent and must be promptly and transparently investigated and vigorously prosecuted.
I believe that the percentage limit in my rule 3 above should be no higher than 1% of world production. For silver, I believe this equates to about 7 million ounces, or 1400 COMEX contracts.
The COMEX must, with no further delay, implement significant improvements to its transparency and fairness as a market, or become irrelevant.
