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SEC’s detailed XBRL tagging requirement

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The Committee on Corporate Reporting ("CCR") of Financial Executives International ("FEI") appreciates the opportunity to share views on our members’ experiences with preparing quarterly filings under the SEC’s detailed XBRL tagging requirement. Overall, CCR member companies are of the view that the process of detailed note tagging may be more difficult than it needs to be and, as a result, may cause delays in the release of SEC filings to investors. As we indicated during our liaison meeting with the Staff on December 3, 2010, we have summarized key findings from a CCR survey that our member companies completed on this topic following the June 30, 2010 filings. We also have canvassed our members to determine whether the issues identified have persisted and whether their experience improved with their September 30, 2010 filings. In addition, we offer our suggestions on how the XBRL filing process might be improved and streamlined.

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