Subject: File No. S7-03-17
From: Vasant D Saini, Ph.D.
Affiliation: President, Advanced Computer Innovations, Inc.

March 1, 2017

Advanced Computer Innovations, Inc., is pleased to comment on the rule the Securities and Exchange Commission has proposed that would require Inline XBRL (iXBRL) filing of tagged data in operating company financial reports and Mutual Fund Risk/Return Summary filings.

Advanced Computer Innovations, Inc., produces EDGARsuite software used to prepare HTML, XBRL and inline XBRL (iXBRL) filings, and also provides EDGAR filing services.

We support the proposed changes, which we believe would:

a) Make filing of computer-readable (XBRL) financial reports easier and in the long run less expensive for filers

b) Make it easier to spot errors and discrepancies in these filings and

c) Make it easier and more intuitive for investors and other users to accurately interpret and understand the interactive data represented in these filings.


Filers currently produce two separate end products (HTML and XBRL), and grapple with a dual focus when preparing these filings (presentation and human readability of the HTML vs. underlying tagging and different-looking rendering of the XBRL). By integrating the human-readable and machine-readable aspects of the filing into a single inline XBRL format, filers can focus on just the one end product, saving time and cost while improving accuracy.

Some filers currently expend unnecessary effort trying to get the XBRL rendering to look like the HTML, and sometimes resort to incorrect tagging to achieve this. The proposed rule would eliminate this consideration entirely since there is no separate XBRL rendering.

Proofing the XBRL rendering for accuracy is currently difficult because the computer-readable data in the separate XBRL rendering has to be compared against the human-readable data in the HTML. The process can be laborious since the same numbers are in different places, and are laid out differently. The proposed rule would eliminate this problem since the human-readable data is itself the computer-readable data they are not two separate copies in different places. This would reduce errors and improve accuracy.


Our EDGARsuite software now includes inline XBRL preparation with no increase in product price, and we provide Inline XBRL filing services at the same or lower cost than for the traditional separate HTML and XBRL process. We do not see any increase in cost to file in the proposed Inline XBRL (iXBRL) format, and in our opinion the proposed rule does not impose any additional burden on filers. On the other hand, preparation time (and hence cost) is reduced because of reasons mentioned above.


Compared to viewing the currently separate XBRL rendering, investors and other EDGAR visitors would find it much easier to view and interpret the interactive data in iXBRL EDGAR filings as a result of the proposed rule. They would view only one human-friendly version of the filing, with the underlying interactive data available very easily, rapidly and intuitively. The experience would be vastly superior to dealing with traditional XBRL rendering.


In conclusion, we believe that the proposed rule is a huge step forward towards making accurate machine-readable reporting easier and less expensive for filers in the long run, while at the same time making the underlying interactive XBRL data easier to access and more useful to investors and EDGAR visitors. We strongly support and commend the SEC on its commitment to leverage this technology with the goal of modernizing financial reporting, enhancing the accuracy and transparency of financial disclosures, and at the same time reducing its cost to filers and improving ease of use and access to this information for investors and other stakeholders.