Ms. Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-1090

Re: Proposed Rule on the Registration of Security-Based Swap Dealers and Major SecurityBased Swap Participants (File Number S7-40-11)

Dear Ms. Murphy:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the Securities and Exchange Commission’s (the “Commission’s”) proposed registration requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”) pursuant to Title VII of the Dodd-Frank Wall
Street Reform and Consumer Protection Act (“Title VII” of “Dodd-Frank”).2

SIFMA generally supports the Proposal and:

• the Commission’s plan to publish a comprehensive Title VII implementation
  proposal;
• the Commission’s (i) attempts to align SBSD and MSBSP registration
  requirements with the Commodity Futures Trading Commission’s (“CFTC’s”)
  proposed registration requirements and (ii) creation of a streamlined registration
  process for SBSDs and MSBSPs already registered with the Commission or the
  CFTC; and
• the Commission’s plan to conduct a holistic review of Commission registration
  requirements.

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