Christopher Kirkpatrick
Secretary of the Commission
Commodity Futures Trading Commission
1155 21st Street, N.W.
Washington, DC 20581

Re: Comments on Draft Technical Specifications for Certain Swap Data Elements

Dear Mr. Kirkpatrick:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to provide the Commodity Futures Trading Commission (the “Commission” or “CFTC”) and its staff (“Staff”) with comments on the Draft Technical Specifications for Certain Swap Data Elements (the “Draft Technical Specifications”).

We welcome the Staff’s decision to seek input from the public regarding the Draft Technical Specifications.3 SIFMA’s members share the Commission’s goal of enhancing the quality and
consistency of reported swap data. We also support the Commission’s efforts to refine and improve swap data reporting requirements. Clear reporting requirements are essential for the Commission to obtain the accurate data it needs to fulfill its regulatory mandates. We believe continued public engagement on these issues, including through further rulemakings to reflect the Draft Technical Specifications (where and when appropriate), will help ensure that appropriate modifications to existing reporting rules are made in order to achieve that objective.

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