OPPOSE Proposed Expansion of CFTC Jurisdiction to OTC Cash Markets

Date 6/7/10

Senator: David Vitter
Washington, DC Office
516 Hart Senate Office Building
Washington, DC 20510

Dear Senator Vitter,

I am a small business owner. The products that I buy and sell at my Firm are rare coins and precious metals. I understand the need to reform parts of the US financial system, and I urge you to focus on the sectors of this complicated system that actually need fixing. The cash markets are NOT broken, and I am opposed to any changes that would disrupt their current efficient functioning.

The Commodity Futures Trading Commission has asked for new authority to regulate the Over-The- Counter (OTC) precious metals cash markets. This new authority would require the CFTC to police transactions where I provide or arrange any type of financing or work in concert with anyone who provides financing, including lay-away and credit card transactions. My small business and my clients’ transactions would be regulated the same way that major futures contracts are policed.

What is being proposed would adversely affect my business and my customers who wish to purchase coins or precious metals for their investments or hobby because my ability to deliver products to my clients effectively will be destroyed. The proposed unreasonable 2-day timeframe for product delivery will render impossible ALL transactions that require shipping, including e-commerce and mail order transactions. Only face-to-face transactions will be legal. The House of Representatives passed a bill that at least has a more reasonable 28-day delivery period.

The CFTC proposal is simply not well thought-out. It will stifle the vibrant coin/precious metals market that has functioned smoothly and efficiently, including during our Country’s financial crisis. Indeed, as paper assets lost value, coins’ and precious metals’ worth increased; these products stabilized investors’ savings and retirement accounts.

The CFTC does not need an extension of its power. As recently as 2008, Congress rejected a similar idea, as did the House of Representatives on similar legislation in the first session of the 111th Congress. Leave our cash markets alone to continue to function efficiently and to provide a stable dimension to our Nation’s financial system. These markets are NOT part of the problem.

My national trade association, the Industry Council for Tangible Assets (ICTA), Inc. (www.ictaonline.org), and I would be happy to work with you and to answer any questions you may have.

Sincerely,

Victor Del Giorno
President, Coin Trader Inc. 

Member ICTA / ANA
   *Rare U.S. Coin Portfolio Planning
   *Precious Metals Advisory
   *Private Wealth Management
 

Direct: 504.267.6004

victor@cointraderinc.com

www.cointraderinc.com

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