Comment Text:
Dear Chairman Gensler and all the Commissioners:
I urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers.
However, I strongly urge you 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 far too high of a threshold in light of the facts about the world silver market.
There are only 3 mining companies in the world who produce more than 25 million ounces of silver per year and only a similar number of industrial consumers using more than that amount. 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 limit of not more than 1500 contract (7.5 million ounce) position limit for silver.
Thank you for considering my comments.
Thank you ,
Mark Millen
