Comment Text:
Dear 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.
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.
Respectfully submitted,
rOBERT lONG
