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 August 31,
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 August
31, 1999, and with respect to agreement of
security purchases and sales, for the period from
July 19, 1999, the date of our last examination,
through August 31, 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 August 31, 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
October 19, 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
August 31, 1999 and from July 19, 1999 (the date
of Deloitte & Touche LLP's last examination)
through August 31, 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 August
31, 1999 and from July 19, 1999 (the date of
Deloitte & Touche LLP's last examination)
through August 31 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
