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Comment for Proposed Rule 76 FR 4752

  • From: William M. Butler
    Organization(s):

    Comment No: 29816
    Date: 2/25/2011

    Comment Text:

    Dear Chairman Gensler and fellow Commissioners

    I know all of you are probably weary of seeing the following (in brief):

    • Jesse’s Café American
    “Open interest in the Comex silver market ROSE 5,799 lots, 18.04 tonnes. Contrary to the judgment of some, the late selling pressure was not long liquidation but fresh short selling.”

    • Zero Hedge:

    FMX Connect Afternoon Gold Fix: "Yesterday’s Sell Off From The 1415 Area Seemed Almost Orchestrated"

    • Ted Butler:

    “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.

    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.”

    *** My motivation in writing this note is to inform you that even the hillbillies up here in the mountains of PA are also finally starting to ‘Get it’ !




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