Comment Text:
Dear Mr Chairman Gensler, Dear Commissioners,
It is crucial that you approve the staff’s proposal on position limits, including limiting exemptions to hedgers but readjust the proposed formula in silver. The current situation allows a position limit of 5,000+ contracts (25 million ounces of silver!) for any single speculator, on an all-months-combined basis. As we all know, there are only 3 mining companies in the world who produce more than 25 million ounces of silver per year and not even more industrial consumers using that amount. You cannot ignore that 5000 contracts is way too high when compared to the size of the world silver market.
Tolerating that any person or entity holding an amount of silver derivatives greater than what 99% of the world’s silver producers and consumers make or use in a year is an obvious market discrepancy and in fact results in tolerating potential manipulations in pricing of this commodity!
The main purpose of your organization and the use of speculative position limits are precisely to prevent such unacceptable situations.
We please ask you to set a 1200 to 1500 contract position limit for silver (7.5 million ounces).
Furthermore, please make sure that any entity cannot use other (related) entities to circumvent this limit.
Sincerely,
George Hilu
