Comment Text:
Dear Chairman Gensler
I respectfully request that you approve the staff's proposal on position limits, as well as limiting exemptions to hedgers. I ask the you consider adjusting the proposed formula in silver. The current formula resulting in position limits of 5000 contracts per speculator on all months combined is equal to 25 million oz. of silver. There are only 3 silver miners in the world who produce more than 25 million oz. of silver per year as well as only a few industrial consumers using more than that same amount. Any one speculator holding the amount of derivatives greater than what 99% of the world's silver producers and consumers make or use each year would obviously have inordinate/unfair pricing power over the market. Please institute a 1500 (7.5 million oz.) position limit for silver
Respectfully
Fred Dutton, MD.