Comment on s7-35-04

November 1, 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 Dear Mr. Katz, The Institute of Management Accountants (IMA) is pleased to submit comments on the XBRL voluntary financial reporting program utilizing XBRL. Our specific comments are below. The IMA has been an active support of XBRL since the organization’s first meeting in 2000. Our support for XBRL begins at the board level, and extends to several very active members on XBRL work groups, consistent support in our flagship magazine, Strategic Finance, and workshops and hands-on training at our national conferences. IMA supports XBRL filing on only a voluntary basis at this time because software vendors are not yet ready for a more comprehensive application and significant training is required for filers.. Larry R. White, CMA, CFM, CPA Chair, Board of Directors IMA Comments on SEC Proposed Rule – 33-8496 XBRL VOLUNTARY FINANCIAL REPORTING PROGRAM ON THE EDGAR SYSTEM About the IMA The Institute of Management Accountants (IMA) is the world's leading organization devoted exclusively to advancing the managerial finance and accounting professions. In addition to gaining access to a worldwide network of 69,000 colleagues in 265 national and international chapters, members ...