Comment for General CFTC Commodity Futures Trading Commission Strategic Plan, 2011-2015

Comment Text:

Dear Chairman Gensler and Fellow Commissioners:
I urge you to approve the staff’s proposal on Position Limits, including limiting exemptions to bona fide hedgers.
However, I strongly recommend that you readjust the proposed formula in silver so as to reduce the proposed 5,000 contracts down to 1,500. This is too high of a threshold in light of the realities of the world silver market.
At 5,000 contracts speculators would have an inordinate pricing power. The purposed of speculative position limits is to prevent such a circumstance.
Please institute a 1,500 contract position limit for silver derivatives.

Respectively submitted,
Debra Michalek