Subject: File No. S7-36-11
From: Joseph P. Herbst

September 7, 2011

XBRL is an unnecessary and non-beneficial regulation placed upon ALL filers, and you should either repeal the entire regulation or, at a minimum, repeal the Detail Tagging of Footnotes portion of it. The cost has been and will continue to be enormous, while the benefits are minimal at best, and form what I've seen and heard the benefits are non-existent. Please remove this cumbersome, expensive and non-beneficial regulation.
Thanks for your consideration.