In light of the unique characteristics of precious metals, the global and interconnected nature of the precious metals markets, and the critical role that large commercial institutions play in maintaining liquidity, we respectfully submit that the Commission has no practical reason for considering the adoption of federal speculative position limits for precious metals. Further, without evidence of excessive speculation in precious metals that may cause "sudden or unreasonable fluctuations or unwarranted changes" in the prices of these products, we submit that the Commission lacks the statutory basis for considering the adoption of federal speculative limits with respect to these products. The market surveillance activities undertaken by the futures exchange, including the existing large trader reporting requirements and position accountability rules, have proven to be more than adequate to govern appropriate behavior on the part of all market participants, promote market integrity and otherwise protect the public interest.