VERITAS Software Corporation
515 N. Whisman Avenue
Mountain View, CA 94043
May 22, 2002
Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Re: File No. S7-08-02
Dear Mr. Katz:
This letter is written in response to the SEC proposal to accelerate the filing of quarterly reports on Form 10-Q and annual reports on Form 10-K "Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports".
The following activities occur after our books and records are closed for each filing period. Our independent public accountants perform quarterly reviews of our financial statements and quarterly audits of our revenue contracts before our earnings results are announced to the public. At year-end our independent public accountants complete their annual audit before our earnings results are announced to the public. The Form 10-Q/Form 10-K is then drafted including all financial statements, notes to financial statements, Management's Discussion & Analysis of Financial Condition and Results of Operations, etc. Our Legal Department and outside counsel assist the Finance Department in the preparation and review of our SEC filings. Our Internal Audit Department also performs certain audit procedures before these documents are filed with the SEC. In addition, our independent public accountants, the Audit Committee of our Board of Directors and the Board of Directors review our Company's Form 10-Q/Form 10-K before being filed with the SEC.
In recent years the accounting rules and pronouncements issued by the Financial Accounting Standards Board and the SEC have not only grown, but have become more complex. An important purpose of these new pronouncements is to make the information and data filed with the SEC more thorough so investors can utilize more and better information when making their investment decisions.
With financial system improvements, companies should be able to generate their financial results in a timelier manner. This has been our experience. However, this savings in time has been more than offset by the increase in time required to prepare quarterly/annual financial statements and required disclosures. This increase in time requirements is a result of the growth and complexity of the new accounting rules. This also increases the time it takes for a thorough review. An increase in the number of reviewers and reviewing levels to assure high quality financial statements requires additional time as well. The net result of these changes is that it takes just as long, if not longer, to prepare our financial statements for filing.
We do not believe it is practical to reduce the filing times for Form 10-Q's to 30 days and Form 10-K's to 60 days. A reduction in filing times could lead to the inefficiency of trying to prepare and review the documents almost simultaneously. There would also be a probable increase in staffing or consultant costs to file these documents in a timely manner. We believe that any potential benefit in providing our financial statements to investors in a shorter time period would be more than outweighed by inefficiencies and increased costs.
Very truly yours,
Kenneth E. Lonchar
Executive Vice President and
Chief Financial Officer
(Principal Financial and Accounting Officer)