SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Securities and Exchange Commission (SEC) on business conduct standards for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs), File No. S7-25-11. The proposed rules would implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) regarding business conduct standards for SBSDs and MSBSPs.  As currently drafted, the SEC’s proposal avoids many of the pitfalls and unintended consequences presented by the Commodity Futures Trading Commission’s (CFTC’s) proposal for external business conduct standards for swap dealers (SDs) and major swap participants (MSPs) and related rulemakings under the Dodd-Frank Act. The groups believe the SEC’s proposal is generally consistent with the legislative intent of the Dodd-Frank Act and provides appropriate protections for SBS counterparties, while providing needed clarity as to the roles, responsibilities and expectations of SBS counterparties.  The groups address some questions about the proposal that have arisen, and recommend ways to clarify certain ambiguities identified by the SEC in its proposal.