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Comment for Proposed Rule 76 FR 4752

  • From: Kenneth W. Castner
    Organization(s):

    Comment No: 30223
    Date: 2/26/2011

    Comment Text:

    I believe that it is very important for you to reconsider the position limit for silver (published at 6,000 with the note that the number could be higher if additional information is obtained).
    It is no secret that the general public believes that existing rules have created unfair trading advantages for a few very large players. Large waves of selling without goods ("naked" shorting), with high margin requirements for the buyers, creates an unfair advantage and contorts real price discovery.
    In fact, COMEX pricing will become more and more irrelevant as buyers circumvent the exchange.
    A good example of this can be found in the quarterly reports of the miners and royalty companies. Hecla, for example, realized an average sale price of $32.51/oz in its last (fourth) quarter. This is considerably more than "spot".
    Please bring some honesty and transparency back to this market. I have no doubt that as soon as the rule is enacted, efforts will be made to find ways to circumvent it. Whatever the final position limit, the short and long side guarantees must be commensurate in ounces and dollars.

    Thank you.

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