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Comment for Proposed Rule 76 FR 4752

  • From: Derrick M Lilly
    Organization(s):

    Comment No: 29731
    Date: 2/25/2011

    Comment Text:

    Dear Chairman Gensler and fellow Commissioners:

    I am writing to urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. The manipulation of physical silver prices through paper trading has gone on for too long and creates a destructive market.

    A position limit of over 5,000 contracts for any single speculator, on an all-months-combined basis is much too high, and threatening to the market based on the world's silver supply. 5,000 contracts is the equivalent of 25 million ounces of silver.

    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 1,500 contract (7.5 million ounce) position limit for silver.

    Best regards,
    Derrick M. Lilly

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