October 29, 2004
October 28, 2004
Mr. Jonathan G. Katz
Secretary
U.S. Securities and Exchange Commission
450 5th Street, N.W.
Mail Stop 6-9
Washington, D.C. 20549-0609
Re: S7-35-04
Proposed Rule: XBRL Voluntary Financial Reporting Program on the EDGAR System
Dr. Mr. Katz:
We are answering your request for comment on the XBRL Voluntary Financial Reporting Program on the EDGAR System from three different perspectives. In some instances these perspectives conflict.
1. As a founding member of the XBRL Consortium we have long supported the use of XBRL to provide greater transparency and flexibility in analyzing company information. In the last several years our company has in fact committed substantial resources to advancing awareness of the use of XBRL, working in concert with the AICPA, in establishing taxonomies to speed the wide spread adoption of XBRL.
2. As an information infomediary we currently use EDGAR-filed data to provide value-added services to more than one million registered users of our various Web sites as well as to corporate and institutional users of financial information. We are now committing substantial resources to tagging expanded fundamental data from SEC EDGAR filings. We also are creating software tools for the retrieval, research and analysis of normalized financial data. We believe that our tools will be of great benefit to users throughout the value chain. We are tagging, compiling and providing a Microsoft Office compatible platform which analyzes data AFTER it has been submitted to the EDGAR system. We believe that our tools will be creating a significant value add for anyone doing analysis of public company financials, whether for investment, analysis or regulation.
3. As a small public company EDGAR Online is deeply committed to good corporate governance and to transparency into our operations. From a practical standpoint, the regulatory landscape over the past two years has placed a heavy financial burden on companies such as ours. An additional cost to provide EDGAR filings in XBRL may not be trivial.
Mr. Jonathan G. Katz
October 28, 2004
Page two
In terms of this specific request for comment we see a good opportunity to test the process and we support the voluntary XBRL tagging of financials to the SEC.
Sincerely,
Susan Strausberg
Chief Executive Officer and President
EDGAR Online, Inc.
50 Washington Street, 9th Floor
Norwalk, CT 06854
Phone: 203-852-5656
Fax: 203-852-5667
Email: susan@edgar-online.com
Web: http://www.edgar-online.com
EDGAR is a federally registered trademark of the U.S. Securities and Exchange Commission SEC. EDGAR Online, Inc. is not affiliated with or approved by the U.S. Securities and Exchange Commission.