Comment on s7-35-04

KPMG LLP 280 Park Avenue New York, N.Y. 10017 th8 Fl November 1, 2004 Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 File No. S7-35-04 XBRL Voluntary Financial Reporting Program on the EDGAR System Release No. 33-8496 Dear Mr. Katz: This letter is the response of KPMG LLP to the Securities and Exchange Commission’s request for comments on its proposed rule regarding the XBRL voluntary financial reporting program on the EDGAR system (the Proposed Rule). Introduction We support the SEC’s initiative because it will facilitate searching, retrieving, and analyzing information using automated means. We believe that the use of eXtensible Business Reporting Language (XBRL) provides a useful tool/format to accomplish these objectives. We believe the use of “tagged” data would provide a wide-range of benefits to preparers, users, and distributors of financial information and other market participants. The Proposed Rule permits a registrant to voluntarily undertake parallel reporting by furnishing XBRL data in addition to the required financial reporting requirements. The voluntary program will allow interested registrants, investors, and others to develop greater familiarity with XBRL. We believe the voluntary program will provide valuable insight into the benefits and challenges of using XBRL. This knowledge can be used to evaluate XBRL reporting for ...