Date:    04/07/2000  4:40 PM

Subject: XBRL Financial Data Standard

Dear Chairman Levitt,
     
        I came across a news article in the 7 April 2000 edition of the London
Financial Times.  The article indicated the AICPA was leading an effort to 
establish standards for financial data on the internet.
     
        I though this was a good idea.  The article also mentioned that Edgar
Data base and alluded to the SEC.  
     
        To make a long story short, it appears as though the SEC does not, as of
today, have a direct input to this body.  Although the article mentions the SEC,
I discussed this matter with Mr Kigin at the SEC Chief Accountants Office who 
assures me that the FT reference was to a non-SEC entity. I invite the SEC to 
consider the XBRL standards and would be happy to receive an invitation to 
provide comments for your staff to review.
     
        I have three concerns at this point:
     
1. Non-inclusion of SEC in XBRL
     
If the XBRL have gone this far without touching base with the SEC, are they 
going to be receptive to comments related to responsibilities of data providers 
promulgated in the 1933/4 Exchange/Securities Acts? More troubling is the 
prospect of me being a lone voice speaking on behalf of the Acts and auditor 
responsibilities in the XBRL standards.   I would like to think that this is not
the case.
     
2. Auditor accountability for certifications
     
My greatest concern is that the proposed standards will allow data generators to
provide data without being held accountable for their financial figures.  Also, 
I am concerned that the auditors in their roles as "data certifiers" will be 
able to get around the liabilities promulgated under Section 11 of the 1933 
Securities Act.  
     
As a data consumer, I would like to have visibility into (a) whether the 
electronic numbers I'm reviewing have been audited or not; and (b) whether the 
auditors plan on taking responsibilities for their certifications as promulgated
in Section 11.  I have my doubts these types of considerations are included in 
the XBRL standards.
     
3.  No visibility to standards
     
At this point, I have no idea what the proposed standards are as they have not 
been provided on the XBRL website as promised.  I have a number of 
recommendations, yet would feel more comfortable if they had the full backing of
the commission staff and were presented on behalf of the owner-investors who 
rely on financial information to make investment decisions.
     
4. Going forward
     
Please let me know whether the SEC plans to engage with the XBRL group--I would 
like to ensure that investors interests are being preserved. I would like to 
make sure that the proposed standards provide a credible basis to increase 
confidence in the US financial reporting system.  Their apparent failure to 
include the SEC in the standard-setting process further undermines my confidence
that investors and data users interests are being carefully considered.  This 
does not take us in the right direction of fostering investor confidence in the 
US financial reporting system.  I would like to see the AICPA offer the SEC an 
invitation to offer inputs to the XBRL standards; and then be happy to respond 
to an invitation from the SEC to provide inputs for a consolidated SEC input to 
the XBRL.
     
Thank you for considering my views.
     
Very respectfully,
     
Greg Siko
     
     
4 References: (Note XBRL, XFMRL, and XML are interchangeable)
     
1. FT Time Article
     
        Plan for financial 'tags' faces web test
        By Adrian Michaels in New York - 7 Apr 2000 01:50GMT
     
http://news.ft.com/ft/gx.cgi/ftc?pagename=View&c=Article&cid=FT3ZSROQQ6C&live=tr
ue&tagid=ZZZGXV4R00C&subheading=global
     
     
2. XBRL Website (Under construction) 
     
       http://www.xbrl.org/
       http://www.networksolutions.com/
     
3. AICPA XFRML Website
     
       http://www.xfrml.org/aicpa/
     
4. Web References for additional information on XFRML
     
       http://www.google.com/search?q=XFRML&sa=Google+Search