Subject: File No. Regulatory Review
From: Michael T. Williams
Affiliation: Williams Securities Law Firm, P.A.

October 5, 2011

As an attorney that represents a number of Smaller Reporting Companies now required to file financial statements in XBRL format, I believe it is essential in this time of economic difficulty in our country that the Office of Inspector General, or other appropriate office, of the SEC to do a cost/benefit study of this requirement.

This study must examine the number of times XBRL financials of smaller reporting companies have been accessed by anyone using the EDGAR system. The number must be very close to zero. So the benefit is correspondingly close to zero. But the cost of these totally unnecessary filings to smaller reporting companies is in the tens of thousands of dollars annually.

This money could be used by smaller reporting companies - the primary engine of job creation in the U.S. - to help create jobs, which is something that is desperately needed in today's economy.