From: Jason Price
Sent: April 28, 2006
To: rule-comments@sec.gov
Subject: File No. 4-515


My name is Jason Price and I work for Deloitte & Touche currently responsible for the development of the firm's risk management system. I read the CFO.com article today titled "Ready or Not, XBRL is Coming" and couldn't agree more with the assessment made about the ability to allow companies to extend the official taxonomies.

Due to the nature of my work, I am looking at XBRL from the analyst side of things. In order to analyze all public companies to assess risk, it is imperative that we compare like kind items under a uniform chart of accounts. We currently have a data provider that does that for us but it was my understanding that XBRL would make this more transparent for us so we could do our ratio analysis and have the ability to drill down to the numbers reported on the financial statement. Our provider "normalizes" the data so we can compare like kind items but this often leads to disagreements in the calculations used.

Anyway, I thought it was a very timely article because I am tasked with creating a large scale risk analysis tool using XBRL data, and if there isn't a standardized way of calculating ratios then XBRL is pretty much useless. I hope that is not the case because XBRL does have a ton of potential.

I am in full support of a “customizable industrial taxonomy” implementation.

Regards,
Jason

Jason Price
AERS Innovative Solutions and Market Intelligence
Deloitte & Touche LLP