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SEC Proposed Rule: “Interactive Data Improvements to Financial Reporting”

Monday, August 4, 2008

The Institute of Management Accountants (“IMA”) is the world's leading association for management accounting and finance professionals. We appreciate the opportunity to provide our views to the Securities and Exchange Commission (the “SEC”) on the Proposed Rule, Interactive Data to Improve Financial Reporting. This letter of comment was prepared by the IMA’s Financial Reporting Committee (the “FRC”) and members of the IMA’s Small Business Financial and Regulatory Affairs Committee (the “SBFRAC”). The FRC is the financial reporting technical committee of the IMA. The SBFRAC represents the smaller companies in IMA’s membership and includes representatives of smaller registrants. Both Committees review and respond to research studies, statements, pronouncements, pending legislation, proposals and other documents issued by domestic and international agencies and organizations. This document represents the views of FRC and SBFRAC and not necessarily the views of IMA or its members individually.

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