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                              October 20, 2020

       Patrick Pedonti
       Senior Vice President and Chief Financial Officer
       SS&C Technologies Holdings, Inc.
       80 Lamberton Road
       Windsor, CT 06095

                                                        Re: SS&C Technologies
Holdings, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 28,
2020
                                                            File No. 001-34675

       Dear Mr. Pedonti:

               We have reviewed your September 3, 2020 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to the comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to the comment, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       August 20, 2020 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Notes to Consolidated Financial Statements
       Note 18. Segment and Geographic Information, page 86

   1.                                                   Please explain further
the following as it relates to the information provided in your
                                                        response to prior
comment 1:

                                                              Provide a
breakdown of your 10 components.
                                                              Tell us the size
of each component and provide the revenue and operating income for
                                                            each.
                                                              Clarify which
costs are allocated based on the budgeted revenue contribution by each
                                                            component, and tell
us what percentage of each component's expenses are comprised
                                                            of allocated costs
versus direct costs.
 Patrick Pedonti
SS&C Technologies Holdings, Inc.
October 20, 2020
Page 2
                Describe the nature of the direct costs that are attributed to
the components.
                Explain further why the exclusion of certain expenses such as
share-based
              compensation, legal settlements, fair value adjustments, etc.
would result in
              component financial information that is not useful to the CODM.
                Describe further the goals and objectives that are discussed at
your weekly staff
              meetings. Tell us whether these are financial or performance
goals and explain how
              you evaluate the progress towards meeting such goals and
objectives.
                You state that the CODM utilizes weekly revenue updates, in
part, to help evaluate
              which resource requests will be fulfilled during the period.
Explain further how
              requests are communicated to the CODM and the factors he
considers in determining
              which will be fulfilled. Also, clarify how each component   s
goals and objectives
              factor into any resource allocation decisions.
                Tell us whether resource allocation discussions occur at your
weekly staff meetings,
              and how these meetings play into the CODM   s consideration for
making resource
              allocation decisions, even at a consolidated level.
                Explain how you manage the budget to actual results throughout
the year.
              Specifically address the actions taken should one of the
components fail to meet their
              revenue or operating income budget goals in a particular period.
                Explain further how the CODM allocates his bonus pool among
each of the
              components and specifically address the strategic initiatives and
other factors that are
              considered. Provide examples of the strategic initiatives and
describe how they are
              measured.

      You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or
Kathleen Collins,
Accounting Branch Chief at (202) 551-3499 with any questions.



FirstName LastNamePatrick Pedonti                               Sincerely,
Comapany NameSS&C Technologies Holdings, Inc.
                                                                Division of
Corporation Finance
October 20, 2020 Page 2                                         Office of
Technology
FirstName LastName