Subject: File No. Regulatory Review
From: Dennis Brovarone, geu
Affiliation: attorney

March 1, 2011

I urge the commission to provide relief for smaller reporting companies from the XBRL requirements. My investigation of the annual cost of available XBRL solutions for small businesses is $10 to $20 thousand dollars for the first two years. I also believe there is little to no advantage to XBRL for hundreds if not thousands of thinly traded OTC companies that have virtually no analyist coverage.

XBRL is a burden to embryonic companies who create jobs in America.