Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I hereby urge you to approve the staff’s proposal on position limits, including limiting exemptions to bona fide hedgers. I would ask you, however, 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, which is too high of a threshold in light of the realities of the world silver market. The silver market, as you know, is in backwardation since Jan 19, 2011. With position limits this situation will be mitigated in the future since it will restore the balance between supply and demand.
Please institute a 1500 contract (7.5 million ounce) position limit for silver.
Respectfully submitted,
Ilia Roussev, Ph.D.
