Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I have been following the goings on of the Comex and the way silver has been handled for many years. We are a country that purports to be fair and a place where everyone is treated equally. In reality that is far from true. Industry get's unfair advantage and can manipulate commodity prices just by the sheer volume of what they can buy. I and countless individual investors want to be treated fairly and have the right to ask for fair position limits.
I echo the sentiments of Ted Butler a highly respected silver analyst who has great expertise in the field of silver. I 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,
Shulamit Lazarus
