Comment Text:
In view of the fact that there has been speculation that JPM and a handful of others are holding positions that may account for more than 50% of the short side in silver it is imperative to have lower limits to guard against the possibility of manipulation. Whether this is true or not, it seems appropriate to have lower limits so that investor have faith in the system and the perception of manipulation is dispelled.
Therefore I would recommend a position limit of no more than 1000 contracts per entity across all dates. This represents 5,000,000 ounces of silver with a market value of over $150,000,000 at today's prices. That seems more than adequate.
