Subject: File No. S7-35-04
From: Gary A. Wicklund
Affiliation: Executive Director, Capricorn Research

October 29, 2004

I have been involved in financial reporting for the insurance industry for over twenty years. Insurance companies are preparing financial and statistical reports for internal and external needs in many different formats. I have seen printed reports generated electronically by companies reentered or cut and pasted into another report either electronically or manually. These have been for GAAP, statutory and cash reporting. In the last three years I have seen the benefits of using XBRL standard tags for reporting. Tag a data element once using a standard and use the data element in several reporting applications.

I have been involved with the development of version 2.1 XBRL taxonomy in U.S. GAAP for Insurance. I have contacts with insurance companies and trade associations. I know there is an interest in participating in the XBRL Voluntary Financial Reporting Program on the Edgar System. I look forward to comments on the Program and XBRL benefits for improving financial reporting.