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 October
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
October 13, 1999, and with respect to agreement
of security purchases and sales, for the period
from August 31, 1999, the date of our last audit,
through October 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;
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 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 October 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
October 26, 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
October 13, 1999 and from August 31, 1999 (the
date of Deloitte & Touche LLP's last audit)
through October 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 October
13, 1999 and from August 31, 1999 (the date of
Deloitte & Touche LLP's last audit) through
October 13, 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
