Mr. Brent Fields
Secretary
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-1090

Re: Statement of General Policy on the Sequencing of the Compliance Dates for Final Rules Applicable to Security-Based Swaps Adopted Pursuant to the Securities Exchange Act of 1934 and the Dodd-Frank Wall Street Reform and Consumer Protection Act (77 Fed. Reg. 35625)

Dear Mr. Fields:

The Securities Industry and Financial Markets Association (“SIFMA”)1 is submitting this letter to provide the U.S. Securities and Exchange Commission (the “SEC” or “Commission”) with further comments in response to its previously proposed policy statement on rule sequencing and implementation (“Sequencing Proposal”), 2 on which SIFMA previously submitted comments on August 13, 2012. SIFMA and its members strongly support regulatory efforts aimed at increasing transparency and reducing risk in the security-based swap (“SBS”) market through appropriate and well-sequenced Title VII implementation. Through the experiences and perspectives of our members, SIFMA is well positioned to assist the Commission in determining the most effective sequencing for meeting its regulatory objectives while avoiding unnecessary disruptions or fragmentation to the SBS market. As new and significant regulatory and market developments have occurred since the submission of our previous comments, we take this opportunity to revisit and provide additional comments for your consideration on some key issues regarding the sequencing of the Commission’s Title VII regime.

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