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Comment for Proposed Rule 76 FR 4752

  • From: John Flocci
    Organization(s):

    Comment No: 33500
    Date: 3/28/2011

    Comment Text:

    Dear Chairman Gensler and fellow Commissioners:

    Subject: Market Position Limits

    Your function is to ensure that markets are fair and transparent for all participants. It has become increasing clear to the average citizen that many and most of our markets are rigged to be successful for only the largest corporations holding the biggest political sway. In order for this country to regain its greatness, it will take leaders willing to stand and make decisions and rulings based upon the highest moral ground. You have a chance to do this by severely limiting market contract positions in the commodity trades. The big trading houses like JP Morgan and HSBC have dominated the silver and gold trade with positions they couldn't possibly cover because they use the no limit like a hammer.

    I urge you to approve, at a minimum, the following proposals:

    (1) Any market position limit should be representative of any a fractional level of that commodities yearly production. Specifically, I ask you to adjust the market position limit for silver to no more than 1,500 contracts (7.5 million ounces of silver). With only three mining companies in the world producing more than 25 million ounces of silver per year. 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.

    (2) Eliminate any grandfathered exemptions. All organizations, entities and individuals must comply with the new position limits regardless of when they took that position. JP Morgan shouldn't be able to maintain Bear Stearns old outrageous short position to the detriment of the market. Everyone must play by the same rules whether they be billionaire or pauper.

    (3) Short positions must be audited by an independent party to verify the party shorting has the commodity, completely unencumbered by counter party agreements, available to produce. Return sanity to the market and ensure only moderate speculative positions as part of a healthy market price discovery process.

    Respectfully submitted,

    John Flocci

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