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The Office of the Comptroller of the Currency’s Quarterly OTC Derivatives report covers the over-the-counter derivatives positions of the U.S. banks. For many years, the only two banks that mattered in the precious metals category were JPMorgan and Citibank. About three years ago, Bank of America burst onto the scene, as a giant new participant in both silver and gold. It quickly became clear that BoA had established an OTC short derivatives position on silver in excess of one billion ounces (mostly as a result of lease/short sale arrangement with JPMorgan). The position was so large that I wrote to the OCC (and other regulators) through my congressman’s office. The OCC replied, but neither confirmed nor denied my allegation that this was an extremely dangerous position for BofA but did agree that it was a serious matter.