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May 18, 2012
VIA EDGAR SUBMISSION Suzanne Hayes, Assistant Director Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549
Re: TD Ameritrade Holding Corporation Form 10-K for the Fiscal Year Ended September 30, 2011 Filed November 18, 2011 Form 10-Q for Quarterly Period Ended December 31, 2011 Filed February 8, 2012 File No. 001-35509
Dear Ms. Hayes:
This letter is in response to your letter dated May 4, 2012. As agreed by phone, the Company will respond to your letter no later than June 1, 2012. The Company requests this additional time in order to ensure that it can provide a complete response to the comments, and to provide adequate time for internal review of our response.
Please feel free to contact Lance Schulz, Managing Director, Accounting, at (402) 827-8804 with any questions.
Very truly yours,
/s/ William J. Gerber Executive Vice President, Chief Financial Officer
cc: Patrick Daugherty Foley & Lardner LLP
David Doyle Ernst & Young LLP
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