Comment Text:
Dear Chairman Gensler and Commissioners:
I ask you to readjust the proposed formula in silver from a position limit of 5,000 contracts to a contract limit of around 1,500. A 1,500 contract limit is right in line with percentages allowed for other commodities. A 5,000 contract limit is too large and allows organizations with the means to manipulate price action. 5,000 contracts is the equivalent of 25 million ounces of silver. This is too high 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 1,500 contract (7.5 million ounce) position limit for silver.
Thank You,
David Jorgenson
