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SEC Comment Letter for SCANSOURCE, INC. (SCSC) (CIK 0000918965) (SCSC) — Apr 9, 2020

SCANSOURCE, INC. (SCSC) (CIK 0000918965)
Date: April 9, 2020 · CIK: 0000918965 · Accession: 0000000000-20-003098

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File numbers found in text: 000-26926

Date
April 9, 2020
Author
Gerald Lyons
Form
UPLOAD
Company
SCANSOURCE, INC. (SCSC) (CIK 0000918965)

Letter

April 9, 2020 Gerald Lyons Executive Vice President and Chief Financial Officer ScanSource, Inc. 6 Logue Court Greenville, South Carolina 29615 Re:ScanSource, Inc. Form 10-K filed August 22, 2019 Form 10-K/A filed October 24, 2019 Form 10-Q filed November 12, 2019 File No. 000-26926 Dear Mr. Lyons: We have reviewed your filings and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-Q for the Interim Period Ended September 30, 2019 Consolidated Financial Statements General, page 38 1.You disclose that on August 20, 2019 you announced plans to divest your physical product distribution businesses in Europe, UK, Mexico, Colombia, Chile, Peru and your Miami-based export operations ("Planned Divestitures"). You further disclose you began a process to market and sell the Planned Divestitures during the September quarter. Please tell us what consideration you gave to presenting the Planned Divestitures as assets held for sale and discontinued operations in accordance with FASB ASC 360-10-45-9 and FASB ASC 205-20-45 for the quarter ended September 30, 2019. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

FirstName LastNameGerald Lyons Comapany NameScanSource, Inc. April 9, 2020 Page 2 FirstName LastName Gerald Lyons ScanSource, Inc. April 9, 2020 Page 2 You may contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services

Show Raw Text
April 9, 2020
Gerald Lyons
Executive Vice President and Chief Financial Officer
ScanSource, Inc.
6 Logue Court
Greenville, South Carolina 29615
Re:ScanSource, Inc.
Form 10-K filed August 22, 2019
Form 10-K/A filed October 24, 2019
Form 10-Q filed November 12, 2019
File No. 000-26926
Dear Mr. Lyons:
            We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Interim Period Ended September 30, 2019
Consolidated Financial Statements
General, page 38
1.You disclose that on August 20, 2019 you announced plans to divest your physical
product distribution businesses in Europe, UK, Mexico, Colombia, Chile, Peru and your
Miami-based export operations ("Planned Divestitures"). You further disclose you began a
process to market and sell the Planned Divestitures during the September quarter. Please
tell us what consideration you gave to presenting the Planned Divestitures as assets held
for sale and discontinued operations in accordance with FASB ASC 360-10-45-9 and
FASB ASC 205-20-45 for the quarter ended September 30, 2019.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameGerald Lyons
 Comapany NameScanSource, Inc.
 April 9, 2020 Page 2
 FirstName LastName
Gerald Lyons
ScanSource, Inc.
April 9, 2020
Page 2
            You may contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services