INDEPENDENT ACCOUNTANTS' REPORT
To the Audit Committee of the Board of Trustees of
Cappiello-Rushmore Trust:
We have examined management's assertion about
Cappiello-Rushmore Trust's (the "Trust")
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 Trust's
compliance with those requirements. Our
responsibility is to express an opinion on
management's assertion about the Trust'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 Trust'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 July 19, 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 Trust;
* Confirmation from Rushmore Trust that the
securities held for the account of the Trust were
held for the account of Rushmore Trust by Mellon
Bank, N.A. ("Mellon"), as agent for Rushmore
Trust;
* Confirmation with Mellon of all securities held
by Mellon in book entry form for the account of
Rushmore Trust;
* Confirmation with brokers that all purchases and
sales outstanding were in agreement with the
Trust's records;
* Reconciliation of all such securities to the books
and records of the Rushmore Trust and the Trust;
and
* Agreement of selected security purchases and
security sales since our last report from the books
and records of the Trust 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
Trust's compliance with specified requirements.
In our opinion, management's assertion that
Cappiello-Rushmore Trust 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 Trust is
fairly stated, in all material respects.
This report is intended solely for the information
and use of management of Cappiello-Rushmore
Trust, the Board of Trustees 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 Cappiello-
Rushmore Trust (the "Trust"), 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 Trust's compliance with the
requirements of subsections (b) and (c) of Rule 17f-
2 as of December 13, 1999 and from July 19, 1999
(the date of Deloitte & Touche LLP's last
examination) through December 13, 1999.
Based on this evaluation, we assert that the Trust
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 July 19, 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
Cappiello-Rushmore Trust
Frank A. Cappiello
Chairman
Timothy N. Coakley
Vice President
