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Comment for Proposed Rule 76 FR 4752

  • From: Christopher Benz
    Organization(s):
    N/A

    Comment No: 30288
    Date: 2/27/2011

    Comment Text:

    Dear Chairman and fellow Commissioners:

    I take this opportunity to request that you address the issue of position limits within the silver market as per the below (reproduced with authors permission):

    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.

    There are only three mining companies in the world who produce more than 25 million ounces of silver per year and only a similar number of industrial consumers using more than that amount. Any speculator holding an amount of silver derivatives greater than what 99% of the world’s silver producers and consumers make or use in a year would have inordinate pricing power. The purpose of speculative position limits is to prevent such a circumstance.

    Please institute a 1500 contract (7.5 million ounce) position limit for silver.

    Further, as a citizen of a foreign (yet generally friendly) nation to your own, I would urge either yourselves or someone within the US Administration to very thoroughly investigate the ongoing claims of price manipulation persistent within the silver market. Silver is mined in this State, and any and all inhibitors to the price of that silver being regulated by anything other than market forces, in effect short changes not only the miners, but also governments and of course this local community. My local community.

    If it is found that the price of silver, and by default the inherent, sovereign wealth of this and other states, has been intentionally suppressed by US citizens to benefit US banks, and/or other organisations, I would request that someone, somewhere within the US inform me as to what the US government and people will do to redress the financial harm wrought upon this my home state, and all other silver producing states?

    Respectfully,

    C M Benz

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