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Comment for Proposed Rule 76 FR 4752

  • From: Brian Rawson
    Organization(s):

    Comment No: 31433
    Date: 3/9/2011

    Comment Text:

    March 9, 2011




    U.S. Commodity Futures Trading Commission

    3 Lafayette Centre

    1155 21st St. NW

    Washington, DC 20581



    Re: CFTC Hearing on position limits



    Dear Commissioners :



    Please change your proposal in silver limits to "no more than 1,500 contracts", start the 60 day comment period on position limits right away, and go about the business of protecting our free markets. The current proposed limit of over 5,000 contracts will not solve the problem of manipulation in silver!



    As I'm sure you are all well aware by now there is a huge problem with concentration and manipulation in the COMEX metals market whereas the markets for gold and silver are controlled by a handful of large commercial traders to the detriment of all other participants. The problem is so big that the true market prices of gold and silver are currently UNKNOWN and until the large concentrated positions are removed the market.



    The regulations that come from this hearing should be designed to both end the current manipulation and remove the potential for future manipulations using concentrated positions. The goal of the CFTC during this hearing should be to develop a fair and viable gold and silver market where no trader or group of traders can intentionally influence price.



    As you know there are thousands of individual gold and silver investors still waiting for some kind of justice for the openly exposed COMEX market rigging crimes of the large banks.



    Large Commercial Short positions that continues to grow day after day without any changes in the supply of physical metal coming out of the mines are still happening to this day even with the recent and growing public awareness!



    With the demand for physical gold and silver BOOMING around the world and very little new mine supply how can you justify the growing Commercial Short position day after day especially by firms not in the business of silver or gold? Clearly this short position is suppressing the prices and with very little new physical supply coming on line these shorts are NAKED SHORTS.



    These NAKED SHORTS are suppressing the price of gold and silver in a market where physical metal demand is booming. This is illegal under commodity laws because futures and options cannot dictate prices for the underlying metals.



    By sitting on your hands you are letting the "controllers" dictate the price of gold and silver. Then it is obvious, that the big banks instigate a market crash in order to cover their naked short positions. How many times must a criminal perform the same illegal act in the same manner before you stop them?



    Thousands can and do take time out of our busy lives' to write to you, and all we small investors ever get from the CFTC is a meek promise like "We'll look into it". Enough with that, do your job!



    The CFTC's reputation will be destroyed after the COMEX defaults on delivery of physical silver that YOU were in charge of regulating. Comments by CFTC Commissioner Michael Dunn saying he is concerned over funding, basically amounted to announcing to the banks that they can go ahead with they're criminal activities, the CFTC is too busy to police the market at the moment! When you the CIVIL SERVANTS sit on your hands and stand by as the obvious manipulations take place YOU, AS AN EMPLOYEE OF THE CFTC WORKING DAY TO DAY, ARE THE PROBLEM! You are EVERYTHING bad about our once great nation. Mr. Dunn, one of your OWN JUDGES blew the whistle on the corrupt CFTC in his resignation letter.



    I certainly hope that the scheduled hearing on COMEX metal concentration limits this time is the REAL DEAL and not some "horse and pony show" designed to pacify angry gold and silver investors without making real changes.



    I hope that you'll request the presence and testimony of Ted Butler and Bill Murphy at this hearing. Why the CFTC hasn't sought more of their input in the years before this historic meeting is without understanding. They are the experts, and it's time to bring in the experts.



    You should also require public position disclosure; Any company that cannot operate an honest gold/silver trading operation without a veil of secrecy should not be allowed to participate in the markets. All positions of large gold/silver trading companies should be made public to both instill confidence in the free market and expose foul play. The benefits of transparency far outweigh the argument that public disclosure would impair the proprietary trading ability of the participants.



    On January 17, 2010 the CFTC was required BY LAW to implement position limits in the COMEX silver market. This date was not a suggestion but a hard fact of law. On January 18th the CFTC became in violation of this law and the appointed CFTC Commissioners should be removed for not doing their jobs.



    What legal authority does the CFTC have the ability to disobey the laws of the US Congress?



    Furthermore on the subject of using silver held in the (SLV) to satisfy contracts:



    JP Morgan is the "Custodian" in iShares Silver (SLV) which boasts a very dubious Prospectus for holding a large amount of physical silver in Trust for SLV investors. This silver is NOT the property of JP Morgan nor should it be considered the physical silver justification for the gigantic COMEX silver short position and should not ever be used to deliver on any contract.



    The obvious conflicts are numerous including:

    - Dual claimed ownership of physical silver by both JPM and SLV shareholders.

    - SLV Prospectus provides no assurances on location, brand, size, or quality standards.

    - SLV Short positions provide for additional multiple ownership claims on silver inventories.

    - There are NO STRICT AUDIT requirements on physical silver held by SLV.

    - Authorized participants have gold/silver leasing operations so multiple claims on the silver is likely.

    Investors in SLV are innocent victims of this physical silver Ponzi Scheme and the CFTC's lack of action in this area has helped legitimize the silver manipulation scam.



    These words were written so many years ago by our Founding Fathers...



    "But when a long train of abuses and usurpations, pursuing invariably the same object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security."





    Brian Rawson

    Augusta, Me.

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