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Comment for Proposed Rule 76 FR 4752

  • From: Arthur J Haddon
    Organization(s):
    Mandarin Investments LLC
    Oriental Investments LLC
    Chater Capital LLC
    AJA Haddon individually

    Comment No: 29849
    Date: 2/25/2011

    Comment Text:


    Dear Chairman Gensler and your fellow Commissioners at the CFTC:

    It is time for you and your colleagues to stand up and be counted and act in the greater public's general interest and not in accordance with the wishes of a few powerful lobby groups, who represent the interests of the denizens of Wall Street and the large banks. We the people, both inside and outside the country, have suffered deeply at the hands of these criminals for many years now and enough is enough. I urge you as a matter of some urgency, to approve your staff’s proposal on position limits, including limiting any ongoing exemptions to these limits now and in the future, to bona-fide hedgers only. I would also ask you, to take a special look at the position limits being proposed for gold and silver. As I understand it, the current proposal under consideration would result in a position limit maximum of over 5,000 contracts for any single speculator or hedger, on an all-months-combined basis. This is way off base, it would seem.

    For example, if applied to the silver market, 5,000 contracts would be the equivalent of 25 million ounces of silver. 25 million ounces of silver is a stunningly high threshold amount, in light of the underlying demand / supply realities of the world silver market.

    There are perhaps only three mining companies in the whole world who produce more than 25 million ounces of silver in any one year and similarly, it is my understanding there are only a very few industrial consumers who might have an underlying demand in their businesses for more than that amount.

    It is surely self evident that any speculator holding a position that is greater than what 99% of the world’s silver producers and consumers make or use in a year, would have inordinate pricing power and an ability to manipulate the market. The purpose of speculative position limits is to prevent such a set of circumstances from occurring.

    The CFTC's mandate is surely to act in the best interests of all of the American people, while setting an example the rest of the world's population would do well to follow.

    It is my strong belief that the Commission needs to set lower position limits that is being contemplated currently and in the case of silver, a 1500 contract (7.5 million ounce) position limit is the right starting point.

    Thank you for giving me the opportunity to comment on your proposals.

    Respectfully submitted,

    Yours faithfully,

    John Haddon

    AJA Haddon
    370 Gulf of Mexico Drive, Unit # 412,
    Longboat Key,
    Florida 34228

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