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Board. The Chairman reported that over the weekend he had spoken to officials of ACS, Conti and Heinold. He had not yet spoken to anyone at Cargill and Precious Metals but expected to do so shortly.

Heinold advised that all customer silver

positions were marked to and margined to the spot price and that all customers were adequately margined. Heinold's total net silver position was under 400 contracts. On the basis of the foregoing, the Board cancelled the action taken on March 28 with respect to Heinold.

As to ACS, the Chairman reported that offi

cials of that firm were opposed to a request for a $50 million letter of credit, but would provide a $15 million letter of credit if so requested. The Board was also informed that ACS had received cash and had reduced silver positions in London. In addition, $34 million in margin calls which were outstanding as of the close of business on March 27 had been reduced by over 50% and loans to member of the Hunt Group were to be brought closer to compliance either by payments or by the deposit of increased collateral. The Board also was informed that the Board of Trade Clearing Corporation had demanded that ACS's parent corporation make a special capital contribution to ACS and that Continental Grain make a special capital contribution to Conti. Similarly, the Chicago Mercantile Exchange was

seeking a special capital contribution from ACS's parent, and a letter of credit from ACS. Counsel reported on telephone discussions with the Audit Section of the Comex compliance staff with respect to ACS and with the senior compliance officer of Conti.

On the basis of all the foregoing, the Board determined not to take any action at that time with respect to ACS or Conti.

ATTACHMENTS OF COMEX CLEARING ASSOCIATION, INC.

E.

1.

2.

Attachment A Original margin rates for silver effective on and after September 10, 1979.

Attachment B Original margin rates for silver effective on and after September 21, 1979.

3.

4.

5.

6.

7.

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Attachment E Original margin rates for silver effective on and after January 7, 1980.

Attachment F Extract from minutes of Board
Meeting of January 27, 1980.

Attachment G

List of Officers and Directors

of Comex Clearing Association.

8.

Attachment H

List of Clearing Members.

Attachment A

RESOLVED, that the following schedules of original margin rates applying to Gold and Silver contracts, be and hereby is adopted, effective on and after September 10, 1979.

SILVER

NET INTEREST

Upon a net interest of 6,000 contracts or less, $5,000 per contract.

Upon a net interest exceeding 6,000 contracts and not over 12,000 contracts, $6,000 per contract upon such excess.

STRADDLE INTEREST

Upon an interest of 500 straddles or less, no margin required.

Upon an interest exceeding 500 straddles and not over 1,000 straddles, $150 per straddle upon such excess ( $75 per contract on each side). Upon an interest exceeding 1,000 straddles, and not over 3,000 straddles, $250 per straddle upon such excess ($125 per contract on each side). Upon an interest exceeding 3,000 straddles and not over 6,000 straddles, $350 per straddle upon such excess ($175 per contract on each side). Upon an interest exceeding 6,000 straddles and not over 12,000 straddles, $450 per straddle upon such excess ($225 per contract on each side).

Upon an interest exceeding 12,000 straddles and not over 18,000 straddles, $550 per straddle upon such excess ($275 per contract on each side).

Attachment B

RESOLVED, that the following schedule of original margin rates applying to Silver contracts be and hereby is adopted and shall be effective on and after September 21, 1979.

SILVER

NET INTEREST

Upon a net interest of 12,000 contracts or less, $7,500 per contract.

STRADDLE INTEREST

Upon an interest of 3,000 straddles or less, $250 per straddle ($125 per contract on each side).

Upon an interest exceeding 3,000 straddles and not over 18,000 straddles, $500 per straddle upon such excess ($250 per contract on each side).

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