Certificate of Accounting of Securities and Similar Investments in the Custody of Management Investment Companies Filed Pursuant to Rule 17f-2 (40-17f2)
September 01 2021 - 12:05PM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND
EXCHANGE COMMISSION
Washington, D.C.
20549
FORM N-17f-2
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]
1.
|
Investment
Company Act File Number:
|
|
Date
examination completed:
|
|
|
|
|
|
814-00235
|
|
July 12, 2021
|
2.
|
State Identification Number:
|
|
AL
|
|
AK
|
|
AZ
|
|
AR
|
|
CA
|
|
CO
|
|
CT
|
|
DE
|
|
DC
|
|
FL
|
|
GA
|
|
HI
|
|
ID
|
|
IL
|
|
IN
|
|
IA
|
|
KS
|
|
KY
|
|
LA
|
|
ME
|
|
MD
|
|
MA
|
|
MI
|
|
MN
|
|
MS
|
|
MO
|
|
MT
|
|
NE
|
|
NV
|
|
NH
|
|
NJ
|
|
NM
|
|
NY
|
|
NC
|
|
ND
|
|
OH
|
|
OK
|
|
OR
|
|
PA
|
|
RI
|
|
SC
|
|
SD
|
|
TN
|
|
TX
|
|
UT
|
|
VT
|
|
VA
|
|
WA
|
|
WV
|
|
WI
|
|
WY
|
|
PUERTO RICO
|
|
|
|
|
|
Other (specify):
|
|
|
|
|
|
|
|
|
|
|
3.
|
Exact name of investment company as
specified in registration statement:
|
|
|
|
Rand Capital Corporation
|
4.
|
Address of principal executive office
(number, street, city, state, zip code):
|
|
|
|
1405 Rand Building, Buffalo, NY 14203
|
INSTRUCTIONS
This Form must be completed by the investment
companies that have custody of securities or similar investments.
Investment Company
1.
|
All items must be
completed by the investment company.
|
2.
|
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.
|
Accountant
3.
|
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 Commission’s
principal office in Washington, D.C., one copy with the regional office for the region in which the investment company’s principal
business operations are conducted, and one copy with the appropriate state administrator(s), if applicable.
|
THIS FORM MUST BE GIVEN
TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
Management
Statement Regarding Compliance With Certain Provisions of the Investment Company Act of 1940
September
1, 2021
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 Corporation’s compliance with the requirements
of subsections (b) and (c) of Rule 17f-2 as of July 12, 2021 and from December 31, 2020 (the date of our last examination) through July
12, 2021.
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 July 12, 2021 and from December 31, 2020 through July 12, 2021, with respect to securities reflected
in the investment account of the Corporation.
|
Rand
Capital Corporation
|
|
|
|
By:
|
|
|
|
/s/
Allen F. Grum
|
|
Allen
F. Grum
|
|
President
and Chief Executive Officer
|
|
|
|
/s/
Daniel P. Penberthy
|
|
Daniel
P. Penberthy
|
|
Executive
Vice President and
|
|
Chief
Financial Officer
|
Report
of Independent Registered Public Accounting Firm
To
the Board of Directors of
Rand
Capital Corporation
We
have examined management’s 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 July 12, 2021.
Management is responsible for the Corporation’s compliance with those requirements. Our responsibility is to express an opinion
on management’s assertion about the Corporation’s compliance based on our examination.
Our
examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards
require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion about compliance
with the specified requirements is fairly stated, in all material respects. An examination involves performing procedures to obtain evidence
about whether management’s assertion is fairly stated in all material respects. The nature, timing, and extent of the procedures
selected depend on our judgement, including the assessment of the risks of material misstatement of management’s assertion, whether
due to fraud or error. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.
Included among our procedures were the following tests performed as of July 12, 2021, and with respect to agreement of security purchases
and sales, for the period from December 31, 2020 (the date of our last examination), through July 12, 2021:
|
●
|
Count
and inspection of all securities located in the vault of the Corporation in Buffalo, New
York without prior notice to management;
|
|
●
|
Reconciliation
of all such securities to the books and records of the Corporation;
|
|
●
|
Agreement
of any additional investments in portfolio companies from the books and records of the Corporation
to the related supporting documentation and/or agreements;
|
We
believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the
Corporation’s compliance with specified requirements.
In
our opinion, management’s 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 July 12, 2021 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
September
1, 2021
Rand Capital (NASDAQ:RAND)
Historical Stock Chart
From May 2024 to Jun 2024
Rand Capital (NASDAQ:RAND)
Historical Stock Chart
From Jun 2023 to Jun 2024