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Comment for Proposed Rule 76 FR 4752

  • From: Peter F Healey
    Organization(s):
    Retired. In the past Traded Refined Petroleum Products for Mobil Oil Corporation in SIngapore, London and New York - 12 years.

    Comment No: 29810
    Date: 2/25/2011

    Comment Text:

    Dear Chairman Gensler and fellow Commissioners:

    I strongly urge you to establish position limits, including limiting exemptions to just bona fide hedgers. Regarding SILVER, which is clearly being manipulated by the large money-center Banks, I ask that you modify the proposed current formula, that 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.

    There are only three 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 1500 contract (7.5 million ounce) position limit for silver.

    Respectfully submitted,

    Peter Healey
    Austin, TX

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