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Comment for Proposed Rule 76 FR 4752

  • From: Greg Tanghe
    Organization(s):

    Comment No: 31802
    Date: 3/16/2011

    Comment Text:

    To the CFTC;
    Thank you for requesting input from the public on the issue of position limits.

    I believe the current restrictions in place today are adversely affecting both producers and consumers—the very parties that the commodity markets were originally created to assist. The solution to the current condition of market concentration in a few hands seems like it might be relatively simple to remedy. And that solution would be to impose a reasonable limitation on how many positions any one entity or individual may hold. Obviously that limit, in order to be considered reasonable, will have to be a number for each commodity which will, at a minimum, curtail any one trading entity (or group of colluding traders) from holding a near monopolistic number of futures contracts.

    Although I do not purport to know the best number of contracts that should be allowed for each tradable commodity, it becomes obvious that the current restrictions in place for silver traders are insufficient in preventing, or even curbing, a concentrated position in a relatively few colluding hands. Under current conditions, it seems evident that price discovery of the silver market is actually being created by “the paper market” rather than the mechanisms of supply and demand in the physical market.

    I feel someone needs to take a serious look at the apparently “highly concentrated in a few hands” silver market and then correct the system. It is broken. CFTC is in a good position for correcting that inequity. Producers and consumers of all markets deserve for the concentration in the silver market to be corrected.

    Thank you for considering and subsequently addressing the important issues of speculator concentration and position limits.

    Greg Tanghe

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