To the Audit Committee of the Board of Directors of
The Rushmore Fund, Inc.:
We have examined management's assertion about The
Rushmore Fund, Inc.'s (the Fund's) compliance with
the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940
(the Act) as of July 19, 1999, included in the
accompanying Management Statement Regarding Compliance
with Certain Provisions of the Investment Company Act
of 1940. Management is responsible for the Fund's
compliance with those requirements. Our responsibility
is to express an opinion on management's assertion about
the Fund's compliance based on our examination.
Our examination was made in accordance with standards
established by the American Institute of Certified
Public Accountants and, accordingly, included examining,
on a test basis, evidence about the Fund's compliance
with those requirements and performing such other
procedures as we considered necessary in the circumstances.
Included among our procedures were the following tests
performed as of July 19, 1999, and with respect to
agreement of security purchases and sales, for the
period from January 13, 1999, the date of our last
examination, through July 19, 1999:
* Confirmation of all securities held by Rushmore
Trust and Savings, FSB (Rushmore Trust) in book entry
form for the account of the Fund;
* Confirmation from Rushmore Trust that the securities
held for the account of the Fund were held for the account
of Rushmore Trust by the Federal Reserve Book Entry System
(the Fed), as agent for Rushmore Trust;
* Confirmation with the Fed of all securities held by
the Fed in book entry form for the account of Rushmore Trust;
* Confirmation with brokers that all purchases and sales
outstanding were in agreement with the Fund's records;
* Reconciliation of all such securities to the books and
records of the Rushmore Trust and the Fund;
* Confirmation of all repurchase agreements with brokers
and agreement of underlying collateral with broker's records;
* Agreement of selected security purchases and security
sales since our last report from the books and records of
the Fund to broker confirmations.
We believe that our examination provides a reasonable basis
for our opinion. Our examination does not provide a legal
determination on the Fund's compliance with specified
requirements.
In our opinion, management's assertion that The Rushmore
Fund, Inc. was in compliance with the requirements of
subsections (b) and (c) of Rule 17f-2 of the Investment
Company Act of 1940 as of July 19, 1999 with respect to
securities reflected in the investment account of the Fund
is fairly stated, in all material respects.
This report is intended solely for the information and use
of management of The Rushmore Fund, Inc., and the Securities
and Exchange Commission and is not intended to be and should
not be used by anyone other than these specified parties.
Deloitte & Touche LLP
Princeton, New Jersey
August 6, 1999
Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of The Rushmore Fund, Inc.
(the Fund), are responsible for complying with the
requirements of subsections (b) and (c) of Rule 17f-2,
"Custody of Investments by Registered Management Investment
Companies," of the Investment Company Act of 1940. We are
also responsible for establishing and maintaining
effective internal controls over compliance with those
requirements. We have performed an evaluation of the
Fund's compliance with the requirements of subsections
(b) and (c) of Rule 17f-2 as of July 19, 1999 and from
January 13, 1999 (last examination date) through July 19,
1999.
Based on this evaluation, we assert that the Fund was in
compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 of the Investment Company Act of 1940 as
of July 19, 1999 and from January 13, 1999 (last examination
date) through July 19, 1999, with respect to securities
reflected in the investment accounts of The Rushmore Fund,
Inc.
Daniel L. O'Connor
Chairman
Timothy N. Coakley
Vice President
