Comment Text:
CTFC commission Members:
For far too long there has been a "wild-west" mentality with respect to allowable open positions in most commodity vehicles. The big banks are allowed to move markets in ways that support and enhance there own positions. Supply and demand imbalances are not allowed if a position is so out-sized it moves the market without any regard to real fundamental variables.
The commission has had almost two years to gather information about the huge imbalances that are and have been created by having out-sized positions in any one vehicle in markets that are over-seen by your authority. Plenty of evidence exists that show how certain markets are manipulated on a daily basis, for example the COMEX price of silver is a laughable example of how these positions are defended at almost the same time each and everyday. The open short interest in silver is well documented however I do not have a problem with someone or some entity being long or short. What I see on a daily basis are attempts to actively suppress the rise of spot silver. Being a retail trader I cannot believe that you at the CTFC have not seen the same price action at virtually the same time points in a given day. Whoever is doing this is not even trying to hide what they are doing. No one, I repeat NO ONE would sell the volume all at once in a relatively thinly traded market unless the overall goal was to actively cap price advances.
The commission needs to implement position size limits at once and not allow any existing positions to be grandfathered into the actual enforcement of these limits. We do not need another half-hearted measure as the type of ban placed on naked shorting that allowed these already illegal positions to be grandfathered into the market. This is an extreme example but pertinent with regards to drafting regulations that talk much but fail to either be enforced or have any meaningful outcome
Simply put...the time has come to act on a mountain of evidence that has been put forth to the committee over the last two years plus. Failure to act on this will only hasten the demise of your own ability to enforce an efficient market that allows both sides of any trade to have a chance to be right or wrong. What we have now is a market that moves at the whim and folly of the entity that has the biggest capital allocation. That is not a free market at all it's just blatant financial terrorism in my opinion.
Respectfully submitted
Chris D. Strabel
