Certificate of Accounting of Securities and Similar Investments in the Custody of Management Investment Companies Filed Pursuant to Rule 17f-2 (40-17f2)
November 24 2021 - 4:05PM
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.
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Investment
Company Act File Number:
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Date
examination completed:
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814-00235
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October
12, 2021
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2.
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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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KY
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LA
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ME
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MA
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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.
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Exact
name of investment company as specified in registration statement:
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Rand
Capital Corporation
4.
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Address
of principal executive office (number, street, city, state, zip code):
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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.
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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 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.
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THIS
FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
Rand
Capital Corporation
14
Lafayette Square, Suite 1405
Buffalo,
NY 14203
Management
Statement Regarding Compliance With Certain Provisions of the Investment Company Act of 1940
November
24, 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 October 12, 2021 and from July 12, 2021 (the date of our last examination) through October
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 October 12, 2021 and from July 12, 2021 through October 12, 2021, 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
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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 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 October 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 October 12, 2021, and with respect to agreement of security purchases
and sales, for the period from July 12, 2021 (the date of our last examination), through October 12, 2021:
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Count
and inspection of all securities located in the vault of the Corporation in Buffalo, New York without prior notice to management;
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Reconciliation
of all such securities to the books and records of the Corporation;
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Agreement
of any additional investments in portfolio companies 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
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 October 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
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