Comment Text:
Dear Chairman Gensler and fellow Commissioners:
I am a small individual investor in precious metals, mainly silver, and not part of any organization. I am just one of the little guys that get rolled over by the manipulations of the big guys via the derivatives market. Funny thing is, it appears the bank that holds much of my silver purchased through iShares SLV ETF, holds positions contrary to their role as custodian. But that is another issue.
I actually downloaded and skimmed through 4752 - Position Limits for Derivatives. I cannot claimed any level of understanding of what is going on within commodities except silver. But that said, this appears to be a step in the right direction. That said, 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,
Just another Small Guy
