Certificate of Accounting of Securities and Similar Investments in the Custody of Management Investment Companies Filed Pursu...
November 07 2018 - 4:33PM
Edgar (US Regulatory)
U.S. 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]
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1. Investment Company Act File Number:
814-00098
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Date examination completed:
October 23, 2018
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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:
Equus Total Return,
Inc.
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4. Address of principal executive office:
(number, street, city, state, zip code)
700 Louisiana Street,
48
th
Floor, Houston, Texas 77002
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INSTRUCTIONS
This Form must be completed by the investment
companies that have custody of securities or similar investments.
Investment Company
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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
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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
Management
Statement Regarding Compliance with
Certain Provisions of the Investment Company
Act of 1940
November 7, 2018
BDO USA, LLP
2929 Allen Parkway, 20
th
Floor
Houston, Texas 77019
We, as members of management of Equus Total
Return, 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 (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 Fund’s compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 as of October 23, 2018, and from June 28, 2018 (the date of our last examination) through October 23, 2018.
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 Act as of October 23, 2018, and from
June 28, 2018 (the date of our last examination) through October 23, 2018, with respect to securities reflected in the investment
account of the Fund.
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Equus Total Return, Inc.
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By:
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/s/ L’Sheryl D. Hudson
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L’Sheryl D. Hudson
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Chief Financial Officer
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Report of Independent
Registered Public Accounting Firm
To the Board of Directors of
Equus Total Return, Inc.
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 Equus Total Return, Inc. (the “Fund”) 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 23, 2018. 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 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 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 October 23, 2018 and with
respect to agreement of security purchases and sales, for the period from June 28, 2018 (the date of our last examination) through
October 23, 2018:
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Count and inspection of all securities located in the vault of the Amegy Bank (the “Custodian”)
in Houston, Texas without prior notice to management;
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for transfer with
brokers, pledgees, or transfer agents; and
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Reconciliation of all such securities to the books and records of the Fund and the Custodian.
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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 Fund’s compliance with
specified requirements.
In our opinion, management’s assertion
that the Fund complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Act as of October 23, 2018
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 and the Board of Directors of the Fund and the Securities and Exchange Commission and is not intended to
be and should not be used by anyone other than these specified parties.
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/s/ BDO USA, LLP
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Houston, Texas
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November 7, 2018
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