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APPENDIX C

COMMODITY EXCHANGE, INC. (“COMEX”)

ANALYSIS OF DELIVERABLE SUPPLY

SILVER FUTURES

In estimating deliverable supply for the Silver Futures contract, Commodity Exchange, Inc. (“COMEX” or 

“Exchange”) relied on long-standing precedent, which provides that the key component in estimating 

deliverable supply is the portion of typical depository stocks that could reasonably be considered to be 

readily available for delivery.

Appendix C to part 38 of the Commodity Futures Trading Commission’s regulations defines deliverable 

supply as “the quantity of the commodity meeting the contract’s delivery specifications that can 

reasonably be expected to be readily available to short traders and saleable by long traders at its market 

value in normal cash marketing channels at the derivative contract’s delivery points during the specified 

delivery period, barring abnormal movement in interstate commerce.”

Approved Depositories and Stock Reporting Requirements

To date, Exchange approved silver depositories are Brinks, Inc., CNT Depository, Inc., Delaware 

Depository Service Company, HSBC Bank, USA, International Depository Services of Delaware, JP 

Morgan Chase Bank NA, Malca-Amit USA, LLC, Loomis, International, Manfra, Tordella & Brookes, and 

Scotia Mocatta. 

Pursuant to the rules of the Exchange, each depository is required to report to the Exchange the level of 

Exchange grade inventory on a daily basis. The inventory shall include eligible and registered silver. 

Eligible silver shall mean all such silver that is acceptable for delivery against the Silver Futures contract 

(i.e., which meets the specifications and approved brands of the Silver Futures contract) for which a 

warrant has not been issued. Registered silver shall mean eligible silver for which a warrant has been 

issued. Specifically, on a daily basis, each depository is required to provide the Exchange (1) the total

quantity of registered silver stored at the depository, (2) the total quantity of eligible silver stored at the 

depository, and (3) the quantity of eligible silver and registered silver received and shipped from the 

depository. 

The silver inventory levels at all Exchange-approved depositories are made publicly available daily on the 

Exchange website1. Further, the rules of the Exchange require an independent inventory audit to be 

performed annually to provide a comprehensive reconciliation of stocks stored at depositories with 

records maintained by both the Exchange and the depository2. 

Deliverable Supply Analysis

The Exchange determined at this time to base its estimates of deliverable supply of silver on registered 

stock as well as such silver stock meeting all specifications of the Silver Futures contract stored at 

Exchange approved depositories. The Exchange recognizes that silver is used as an investment vehicle 

and as such some silver stock may be held as a long-term investment. While surveys conducted 

indicated no clear consensus as to how much silver is dedicated to long term investments, the Exchange, 

in an effort to represent a conservative deliverable supply that may be readily available for delivery, made 

a determination to discount from its estimate of deliverable supply 50% of its reported eligible silver at this 

1

http://www.cmegroup.com/market-data/reports/registrar-reports.html

2

http://www.cmegroup.com/rulebook/NYMEX/1/7.pdf
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time. The Exchange may, at a later date, decide to estimate those stocks and include them in future 

deliverable supply estimates.

Table 1 below provides the monthly inventory average of each of registered and eligible silver stored at 

Exchange-approved depositories for the period beginning January 2018 through December 2020. 

Over the most recent three-year period beginning January 2018 through December 2020, the monthly 

average registered silver was 17,935 futures equivalent contracts. The monthly average eligible silver 

was 21,827 futures equivalent contracts accounting for a 50% discount. Based on the foregoing, the 

Exchange estimates monthly deliverable supply at approximately 39,762 futures equivalent contracts. 

The current spot month position limit of 1,500 contracts represents 3.77% of the estimated monthly 

deliverable supply.

At this time, the Exchange does not account for silver stock meeting all specifications of the Silver

Futures contract that is stored at depositories other than those approved by the Exchange and which can 

be moved economically into such Exchange-approved depositories consistent with Appendix C of Part 

38. The Exchange may, at a later date, decide to estimate those stocks and include them in future 

deliverable supply estimates.

Table 1: Monthly Average Stock Levels at Exchange Depositories 

 (in Silver Futures equivalent contracts)

Month

Average 

Eligible 

Inventory (with 

50% reduction)

Average 

Registered 

Inventory

Average 

Total 

Inventory

Jan-18 20,097 9,066 29,163

Feb-18 20,370 9,145 29,514

Mar-18 19,692 11,790 31,481

Apr-18 20,134 12,250 32,384

May-18 20,002 13,692 33,694

Jun-18 20,447 13,594 34,041

Jul-18 20,229 15,639 35,868

Aug-18 20,603 16,551 37,154

Sep-18 20,665 17,223 37,888

Oct-18 21,267 15,288 36,555

Nov-18 20,969 16,696 37,665

Dec-18 20,935 17,167 38,102

Jan-19 20,946 17,065 38,011

Feb-19 20,846 17,749 38,595

Mar-19 20,747 18,820 39,567

Apr-19 21,520 18,124 39,644

May-19 21,400 18,504 39,904

Jun-19 21,639 17,520 39,159

Jul-19 21,431 18,655 40,085
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Aug-19 22,073 18,200 40,273

Sep-19 23,056 16,807 39,863

Oct-19 23,461 16,012 39,474

Nov-19 23,611 15,734 39,345

Dec-19 22,996 17,316 40,312

Jan-20 23,648 16,786 40,434

Feb-20 24,133 16,145 40,278

Mar-20 24,058 16,331 40,390

Apr-20 23,583 16,523 40,106

May-20 22,359 17,898 40,257

Jun-20 22,654 17,993 40,647

Jul-20 19,929 25,700 45,629

Aug-20 20,929 25,900 46,829

Sep-20 22,281 28,089 50,371

Oct-20 24,221 27,754 51,974

Nov-20 24,453 27,967 52,420

Dec-20 24,386 29,965 54,351

3-year 

average

21,827 17,935 39,762

Source: CME Group

The proposed spot month position limit for the Silver Futures contract is 3,000 contracts. which represents 

7.54% of deliverable supply for the most recent 3-year period. This is proposed to be effective with the 

April 2021 contract month and beyond.