CERTIFICATE OF
ACCOUNTING OF SECURITIES AND SIMILAR
INVESTMENTS IN THE CUSTODY OF
MANAGEMENT INVESTMENT COMPANIES
Pursuant to Rule
17f-2
[17 CRF
270.17f-2]
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1. Investment Company Act File Number:
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Date examination completed:
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814-00235
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December 31, 2017
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2. State Identification Number:
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AL
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AK
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AZ
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AR
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CA
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CO
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CT
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DE
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DC
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FL
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GA
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HI
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ID
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IL
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IN
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IA
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KS
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KY
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LA
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ME
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MD
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MA
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MI
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MN
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MS
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MO
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MT
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NE
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NV
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NH
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NJ
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NM
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NY
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NC
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ND
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OH
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OK
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OR
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PA
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RI
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SC
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SD
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TN
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TX
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UT
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VT
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VA
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WA
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WV
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WI
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WY
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PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in registration statement:
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Rand Capital Corporation
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4. Address of principal executive office (number, street, city, state, zip code):
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2200 Rand Building, Buffalo, NY 14203
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INSTRUCTIONS
This Form
must be completed by the investment companies that have custody of securities or similar investments.
Investment Company
1.
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All items must be completed by the investment company.
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2.
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Give this Form to the independent public accountant who, in compliance with Rule
17f-2
under the Act and applicable state law, examines securities and similar investments in the
custody of the investment company.
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Accountant
3.
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Submit this Form to the Securities and Exchange Commission and appropriate state securities administrators when filing the certificate of accounting required by Rule
17f-2
under
the Act and applicable state law. File the original and one copy with the Securities and Exchange Commissions principal office in Washington, D.C., one copy with the regional office for the region in which the investment companys
principal business operations are conducted, and one copy with the appropriate state administrator(s), if applicable.
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THIS
FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
Management Statement Regarding Compliance With Certain Provisions of the Investment Company Act
of 1940
March 27, 2018
Freed Maxick CPAs, P.C.
424 Main Street, Suite 800
Buffalo, NY 14202
To Whom It May Concern:
We, as members of management of Rand
Capital Corporation (the Corporation), 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 (the Act). We are also responsible for establishing and maintaining effective internal controls over compliance with those requirements. We have performed an evaluation of
the Corporations compliance with the requirements of subsections (b) and (c) of Rule
17f-2
as of December 31, 2017 and from October 13, 2017 (the date of our last examination) through
December 31, 2017.
Based on this evaluation, we assert that the Corporation 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 31, 2017 and from October 13, 2017 through December 31, 2017, with respect to securities reflected in the investment account of
the Corporation.
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Rand Capital Corporation
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By:
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/s/ Allen F. Grum
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Allen F. Grum
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President and Chief Executive Officer
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/s/ Daniel P. Penberthy
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Daniel P. Penberthy
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Executive Vice President and Chief
Financial
Officer
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Report of Independent Registered Public Accounting Firm
To the Board of Directors of
Rand Capital Corporation
We have examined managements assertion, included in the accompanying Management Statement Regarding Compliance With Certain Provisions of the Investment
Company Act of 1940, that Rand Capital Corporation (the Corporation) complied with the requirements of subsections (b) and (c) of Rule
17f-2
under the Investment Company Act of 1940 (the
Act) as of December 31, 2017. Management is responsible for the Corporations compliance with those requirements. Our responsibility is to express an opinion on managements assertion about the Corporations
compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board
(United States) and, accordingly, included examining, on a test basis, evidence about the Corporations 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 31, 2017, and with respect to agreement of security purchases and sales, for the period from October 13, 2017 (the date of our last examination), through December 31, 2017:
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Count and inspection of all securities located in the vault of the Corporation in Buffalo, New York;
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Reconciliation of all such securities to the books and records of the Corporation;
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Agreement of additional investment in one existing portfolio company from the books and records of the Corporation to the related supporting documentation and/or agreements;
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We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Corporations
compliance with specified requirements.
In our opinion, managements assertion that the Corporation complied with the requirements of subsections
(b) and (c) of Rule
17f-2
of the Investment Company Act of 1940 as of December 31, 2017, with respect to securities reflected in the investment account of the Corporation is fairly stated, in
all material respects.
This report is intended solely for the information and use of management and the Board of Directors of the Corporation and the
Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.
Buffalo, New York
March 27, 2018
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