INDEPENDENT ACCOUNTANTS' REPORT
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") compliance with the
requirements of subsections (b) and (c) of Rule 17f-2
under the Investment Company Act of 1940 (the "Act")
as of December 13, 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 December 13, 1999, and
with respect to agreement of security purchases and
sales, for the period from October 13, 1999 (the date of
our last examination) through December 13, 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;
* Reconciliation of all such securities to the books and
records of Rushmore Trust and the Fund;
* Confirmation with a broker of the Fund's repurchase
agreement; and
* Agreement of selected security purchases and
security sales or maturities 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 December
13, 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. the Board
of Directors 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
January 20, 2000
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 December 13, 1999 and from October 13, 1999
(the date of Deloitte & Touche LLP's last examination)
through December 13, 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 December 13, 1999 and from October 13,
1999 (the date of Deloitte & Touche LLP's last
examination) through December 13, 1999, with respect
to securities reflected in the investment accounts of The
Rushmore Fund, Inc.
Daniel L. O'Connor
Chairman
Timmothy N. Coakley
Vice President
