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Comment for Proposed Rule 76 FR 4752

  • From: Richard Bernard
    Organization(s):
    Investor

    Comment No: 29891
    Date: 2/25/2011

    Comment Text:


    There is is a crime in progress in this country of LAW.

    Would it not be easier for the people to ask for "end the C F T C " after all what is the point of paying regulators that do nothing. And admit simply we are lawless­.

    Fair and appropriate position limits in silver should be NO MORE than 1,500 contracts or 7.5M ounces. The current proposed limit of over 5,000 contracts WILL NOT SOLVE THE PROBLEM OF MANIPULATION IN SILVER! The 1,500 contract limit is the correct amount and is STILL greater than any other current concentration in physical commodities traded on the COMEX.



    Dear Chairman Gensler and fellow Commissioners:

    I 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. 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,

    Richard Bernard

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