Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I support Ted Butler's suggestion below and in addition I think transparencies of what the large speculators (including their subsidiaries) hold should be revealed to the public. Otherwise, any banks (which they are not really in the business of mining or using silver anyway) may end up holding a concentrated position of more than my suggested 1500 contracts by setting up different entities within the company.
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,
EK
