Comment Text:
To 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.
Given the reality and sordid details of the concentrated short position in silver that has come to light over the past few years, it would prove self-incriminating and incredible to actually put forth a position limit that benefits less than a handful of market participants and enables manipulation. This would, in effect, cause a backlash from the investing public and damage market participation far beyond whatever damage it is you are trying to prevent by instituting such a fantastical limit in a tiny market such as silver.
Please institute a 1500 contract (7.5 million ounce) position limit for silver.
Respectfully submitted,
