罗斯汀·贝南(Rostin Behnam)
代理主席
美国商品期货交易委员会
三拉斐特中心
1155 21日街,NW
华盛顿特区20581
亲爱的代理主席贝南:
您在2月1日表示,委员会正在密切监视白银市场的近期活动,得出结论认为,该机构在监视这些市场的欺诈和操纵行为方面仍保持警惕。
如您所知,大部分投资公众都认为,涉嫌欺诈和操纵白银市场的主要根源是有记录的COMEX白银期货大量集中空头头寸。
委员会已经发现这个问题足够重要,可以在2004年和2008年5月发表公开信,讨论这个问题,但是显然这个问题并没有消失,实际上已经加剧了。在实际生产中,COMEX白银期货的集中空头头寸高于其他任何商品的集中空头头寸,人们怀疑这种空头头寸会抑制白银价格。
更重要的是,委员会自己的交易商承诺报告涵盖了截至2月2日当周的头寸,清楚地表明,COMEX白银期货的四大空头增加了6672份新的空头合约(3340万盎司),建立了净空头头寸。 65,262张合约(3.263亿盎司),是近一年来的最高水平,而最大的多头急剧减少了他们的多头头寸,进一步强烈表明,大空头部分受到了任何操纵。
一个理性的人很难理解,在广泛的现货白银市场紧缩甚至无货的迹象下,只有4个交易者的集中空头头寸如何合法地急剧增加。如果没有这种集中的卖空,白银的价格涨幅不可能超过他们的涨幅。
由于委员会上次处理COMEX白银期货集中空头头寸已有近13年的时间,因此委员会此时公开处理此事符合公共利益。
我敦促委员会解释仅由4个交易商组成的如此大的空头头寸如何不会人为地抑制白银价格,或者作为替代,命令将其价格下调至与其他受管制商品可比的水平。
真挚地,
西奥多·巴特勒
Interest in silver and concerns about its price being artificially suppressed by excessive short selling are now at levels never seen before. While those concerns are well-founded, in my opinion, too often the remedy for what to do about it is less clear.
Since silver and silver futures trading is regulated by the US Commodity Futures Trading Commission (CFTC), it is the statutory first line of defense against market manipulation. Here’s something that will take only a few moments and has always worked in the past in assuring the agency will, at least, address the issue directly.
If you are concerned that the silver price is being artificially influenced by excessive and manipulative short selling, please email or send a copy of the enclosed letter to the CFTC. If you would like, substitute my name with your name, but please send it to the addresses of the Commissioners I’ve included.
For US citizens, please take an extra few minutes to send a copy to your local representative or senator, asking them to request the CFTC address this matter. I can further assure you that the agency will respond to every inquiry from every elected official who contacts it. Interestingly, this is one of the few completely non-partisan issues of the day, so politics shouldn’t determine whether you contact your elected representatives and senators.
Rostin Behnam
Acting Chairman
US Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
Dear Acting Chairman Behnam;
On Feb 1, you stated that the Commission was closely monitoring recent activity in the silver markets, concluding that the agency remains vigilant in surveilling these markets for fraud and manipulation.
As I am sure you are aware, a large segment of the investing public feels that the main source of an alleged fraud and manipulation of the silver market is the documented large concentrated short position in COMEX silver futures.
The Commission had found this issue to be significant enough to post public letters addressing the matter in May of both 2004 and 2008, but clearly the issue has not gone away and has, in fact, intensified. In terms of real world production, the concentrated short position in COMEX silver futures towers over the concentrated short positions in any other commodity, raising suspicions that it is this short position suppressing the price of silver.
More to the point, the Commission’s own Commitments of Traders report covering positions for the week ended Feb 2, clearly indicate that the 4 largest short sellers in COMEX silver futures added 6672 new short contracts (33.4 million oz), establishing a net short position of 65,262 contracts (326.3 million oz), their highest level in nearly a year, while the largest longs sharply reduced their long positions, further strongly suggesting any manipulation was on the part of the large shorts.
It is hard for a reasonable person to understand how the concentrated short position of only 4 traders can legitimately increase so sharply at a time of widespread evidence of tightness and even unavailability in the wholesale physical silver market. It would have been impossible for silver prices not to have risen much more than they did without this concentrated short selling.
Since it has been nearly 13 years since the Commission has last addressed the issue of the concentrated short position in COMEX silver futures, it would be in the public interest for the Commission to publicly address the matter at this time.
I would urge the Commission to explain how such a large short position by only 4 traders would not suppress the price of silver artificially, or as an alternative, move to order it reduced to levels comparable to other regulated commodities.
Sincerely,
Theodore Butler