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Comment for Proposed Rule 76 FR 4752

  • From: Stewart Armstrong
    Organization(s):
    Seacoast Publishing

    Comment No: 30416
    Date: 2/27/2011

    Comment Text:

    Dear Chairman Gensler and fellow Commissioners:

    We've been closely watching what has been occurring in the silver pits for the last ten years and quite honestly this goes far beyond the confines of your particular area of expertise. This goes to what is good for America.

    America can come back from the deceptions but only if people such as yourselves stand up for what is true and honest.

    When two or three large institutions control 20-100 times an entire commodities market, something is out of whack. When people who stand up and try and tell the world the truth are hung out to dry or run over--literally, something is out of whack.

    When the financial markets of any country are controlled at the expense of the country, something is amiss.

    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.

    Sincerely,

    D. Stewart Armstrong
    Publisher

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