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SEC Comment Letter for BISYS GROUP INC (CIK 0000883587) — Aug 16, 2005

BISYS GROUP INC (CIK 0000883587)
Date: Aug. 16, 2005 · CIK: 0000883587 · Accession: 0000000000-05-042220

AI Filing Summary & Sentiment

File numbers found in text: 001-31254

Date
August 12, 2005
Author
Amit Pande
Form
UPLOAD
Company
BISYS GROUP INC (CIK 0000883587)

Letter

Mail Stop 4561 August 12, 2005 The BISYS Group, Inc. 90 Park Avenue New York, NY 10016 Attn: Edward S. Forman

Re: The BISYS Group, Inc. Item 4.02 Form 8-K Filed July 25, 2005 File No. 001-31254

Dear Mr. Forman:

We have reviewed your filing and have the following comment. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 8-K

1. We note from your Form 8-K filed April 19, 2005 that your Audit Committee began its investigation into the accounting errors prior to that date. Tell us when and how you intend to file your restated financial statements identified in this filing.

As appropriate, please respond to this comment within five business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your and response to our comment.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the disclosure in the filing;

* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

* the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.

You may contact Benjamin Phippen, Staff Accountant at (202) 551- 3697 or me at (202) 551-3423 if you have any questions.

Sincerely,
Amit Pande
Assistant Chief Accountant

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 4561

								August 12, 2005

The BISYS Group, Inc.
90 Park Avenue
New York, NY 10016
Attn:  Edward S. Forman

Re:	The BISYS Group, Inc.
	Item 4.02 Form 8-K
      Filed July 25, 2005
	File No. 001-31254

Dear Mr. Forman:

      We have reviewed your filing and have the following comment.
Please be as detailed as necessary in your explanation.  In our
comment, we may ask you to provide us with more information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K

1. We note from your Form 8-K filed April 19, 2005 that your Audit
Committee began its investigation into the accounting errors prior
to
that date. Tell us when and how you intend to file your restated
financial statements identified in this filing.

       As appropriate, please respond to this comment within five
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your and response to our comment.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Benjamin Phippen, Staff Accountant at (202)
551-
3697 or me at (202) 551-3423 if you have any questions.

							Sincerely,

							Amit Pande
							Assistant Chief Accountant

</TEXT>
</DOCUMENT>