Re: File Number S7-11-08: Proposed Rule for Interactive Data

(“AIA”) appreciate the opportunity to comment on a proposed rule of the Securities and Exchange Commission (“SEC ” or “Commission”) to require the filing of financial statement information using eXtensible Business Reporting Language (“XBRL”). The ACLI is a trade association whose 353 member companies account for 93 percent of the life insurance industry’s total assets in the United States, 93 percent of life insurance premiums and 94 percent of annuity considerations. The AIA is the leading insurance trade association representing over 350 property and casualty insurance companies that write combined premiums in excess of $123 billion each year. Although we support the Commission’s effort to implement a robust filing system, we are concerned with the current status of the XBRL taxonomies with respect to the insurance industry, the proposed timing for implementation of XBRL, and the lag of specific examples in the rule. AIA has previously submitted comments to the SEC and XBRL-US, expressing concerns with the latest version of the taxonomy that would be used to implement an XBRL filing requirement. Although the latest version of the taxonomy is intended to provide mor