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.
Ted Butler is urging a position limit of 1500 contracts, which seems reasonable. If you feel that is too low, a position limit of 2500 contracts might be a good compromise. After several months experience, you could revisit this issue and revise the limit up or down as necessary.
Respectfully submitted,
Herbert Hedgpeth
