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Comment for Proposed Rule 76 FR 4752

  • From: dave rogers
    Organization(s):
    strannck contracting

    Comment No: 31076
    Date: 3/7/2011

    Comment Text:

    To whom it may concern;

    I have just read the following Ted Butler's recent analysis of the silver COT and Bank Participation Report
    "JPMorgan was the sole seller to the raptors’ buying, resulting in the big increase in JPM’s short position".

    "My own guess is that the JPMorgan silver trader thought he had no choice but to sell many more contracts short in order to control the price and protect their existing short position. That’s because there was no one else left to sell. If JPMorgan didn’t sell, no one else would have (at prevailing prices).That left JPMorgan as the sole silver seller, as the COT and Bank Participation Reports clearly document. Please think about this.

    "We know that concentration in any market is to be avoided. The whole thrust of commodity law goes towards preventing concentration. We know that the ideal profile of a free market is where a wide diversity of market participants competes on both the buy and sell sides of the market. We also know that the most extreme state of concentration possible is where there is, effectively, only one buyer or one seller. Therefore, what the latest COT and Bank Participation Reports just confirmed was that the most extreme form of concentration possible just occurred during the latest reporting week.

    "This is the key point – what would have happened if JPMorgan hadn’t sold short the additional 6,000 silver contracts (30 million oz) when they did? Asked differently, in the current market conditions, what price would have been required to induce other market participants to sell the 6,000 contracts if JPMorgan hadn’t sold? My guess is that would have taken a price over $40 or $50 to attract that much legitimate selling. The fact that JPMorgan was the sole seller is the clearest proof possible that silver has been manipulated"

    Based on Mr. Butler's summation, I believe the question isnt 'is there manipulation in the silver futures's market?' but is 'why isnt the CFTC doing anything about it?'

    In the worst tradition of bureaucratic malaise and ineffectiveness, the CFTC has 'studied' this matter ad nauseum, while this 'crime in progress' continues.

    I can only speculate why the CFTC allows this. Does the CFTC believe a rising silver price will badly portray the state of the economy and the dollar, and that therefore the CFTC is performing a civic duty to the nation, by not enforcing it's policies guarding against manipulation, which is it's mandate?

    The CFTC's inaction enables the further deterioration of our financial system. If the CFTC believes that by enabling banks to stifle silver, they are serving the greater good, the CFTC should realize that the most immediate good of their inaction is for the bottom line of JP Morgan's Commodity Trading Desk.

    If the CFTC believes that pandering to Banks heavily short silver like JPMorgan bolsters the economy serves the people, the CFTC should read Jamie Dimon's 2010 compensation package to see whose financial interests are being bolstered, if the CFTC even cares.







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