SEC Comment Letter for SCANSOURCE, INC. (SCSC) (CIK 0000918965) (SCSC) — May 31, 2007
SCANSOURCE, INC. (SCSC) (CIK 0000918965)
Date: May 31, 2007 · CIK: 0000918965 · Accession: 0000000000-07-026908
AI Filing Summary & Sentiment
File numbers found in text: 000-26926
Letter
April 23, 2007 Room 4561 Mr. Michael L. Baur Chief Executive Officer Scansource, Inc. 6 Logue Court Greenville, SC 29615
Re: Scansource, Inc. Form 8-K Filed April 20, 2007 File No. 000-26926
Dear Mr. Baur:
We have reviewed the above referenced filing and have the following comment. Please note that we have limited our review to the matters addr essed in the comment below. Where indicated, we think you shoul d revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your explanation. In our comment, we ask you to provide us with supplemental information so we may better understand your disclosure. Af ter reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our re view 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 comment or on 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 filed on April 30, 2006
Item 4.02(a) Non-reliance on Previously Issued Financial Statements or a Related Audit Report or Completed Interim Review 1. Please amend your Form 8-K to state cl early whether you have concluded that your financial statements for periods pr ior to those included in your fiscal 2006 annual report should not be relied upon. Y our current disclosure indicating that “perhaps” these financial statements shoul d not be relied upon is not sufficiently specific regarding the status of those financial statements within the context of the Item 4.02(a) of Form 8-K.
* * * * * *
Mr. Michael L. Baur Scansource, Inc. April 23, 2007 Page 2 Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review. Please understand that we may have addi tional comments after reviewing any amendment and your responses to our comments.
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 in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating 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 comments, 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 comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advise d that the Division of Enforcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
You may contact David E dgar, Staff Accountant, at (202) 551-3459 or the undersigned at (202) 551-3451 if you have any questions regarding this comment.
Sincerely,
Mark Kronforst
Accounting Branch Chief
Show Raw Text
April 23, 2007
Room 4561
Mr. Michael L. Baur
Chief Executive Officer
Scansource, Inc.
6 Logue Court
Greenville, SC 29615
Re: Scansource, Inc.
Form 8-K Filed April 20, 2007
File No. 000-26926
Dear Mr. Baur:
We have reviewed the above referenced filing and have the following comment.
Please note that we have limited our review to the matters addr essed in the comment
below. Where indicated, we think you shoul d revise your document in response to this
comment. If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your
explanation. In our comment, we ask you to provide us with supplemental information so
we may better understand your disclosure. Af ter reviewing this information, we may or
may not raise additional comments.
Please understand that the purpose of our re view 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 comment or on 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 filed on April 30, 2006
Item 4.02(a) Non-reliance on Previously Issued Financial Statements or a Related Audit
Report or Completed Interim Review
1. Please amend your Form 8-K to state cl early whether you have concluded that
your financial statements for periods pr ior to those included in your fiscal 2006
annual report should not be relied upon. Y our current disclosure indicating that
“perhaps” these financial statements shoul d not be relied upon is not sufficiently
specific regarding the status of those financial statements within the context of the
Item 4.02(a) of Form 8-K.
* * * * * *
Mr. Michael L. Baur
Scansource, Inc.
April 23, 2007 Page 2
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your responses to our comments.
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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating 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 comments, 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
In addition, please be advise d that the Division of Enforcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact David E dgar, Staff Accountant, at (202) 551-3459 or the
undersigned at (202) 551-3451 if you have any questions regarding this comment.
Sincerely,
Mark Kronforst
Accounting Branch Chief