MACC
PRIVATE EQUITIES, INC.
October
23, 2009
KPMG,
LLP
Suite
600
4747
Executive Drive
San
Diego, CA 92121
Ladies
and Gentlemen:
We, as
members of management of MACC Private Equities Inc. (the Company), 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 Company’s
compliance with the requirements of subsections (b) and (c) of rule 17f-2 as of
September 30, 2009 and from July 15, 2009 through September 30,
2009.
Based on
this evaluation, we assert that the Company was in compliance with the
requirements of subsections (b) and (c) of rule 17f-2 of the Investment Company
Act of 1940 as of September 30, 2009, and from July 15, 2009, through September
30, 2009, with respect to securities reflected in the investment account of the
Company.
Very
truly yours,
MACC
Private Equities Inc.
By
/s/ Marilyn
Benge_________
Marilyn
Benge, Controller
/s/ Derek
Gaertner_________
Derek
Gaertner, CFO
/s/ Travis
Prentice_________
Travis
Prentice, President
Report
of Independent Registered Public Accounting Firm
The Board
of Directors
MACC
Private Equities 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 MACC Private Equities Inc. (the Company) complied with
the requirements of subsections (b) and (c) of rule 17f-2 under the
Investment Company Act of 1940 as of September 30, 2009. Management is
responsible for the Company’s compliance with those requirements. Our
responsibility is to express an opinion on management’s assertion about the
Company’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 Company’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 September 30, 2009 and with respect to agreement of security
purchases and sales for the period from July 15, 2009 (the date of our last
examination) through September 30, 2009:
|
·
|
Count
and inspection of all securities located in the vault of Cedar Rapids Bank
and Trust in Cedar Rapids, Iowa (the
Bank)
|
|
·
|
Reconciliation
of all such securities to the books and records of the Company, including
the items noted below:
|
|
·
|
The
Company’s certificate of its investment in 1,015.79 Class A1 Preferred
Membership Units dated September 3, 2009 of Handy Industries, LLC was not
in the Bank’s vault on September 30, 2009. We confirmed receipt
of the Class A1 Preferred Membership Units on October 20, 2009 with the
Bank and observed the certificates in the Bank’s vault on October 23,
2009.
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|
·
|
Agreed
all security purchases and security sales, since the date of our last
report from the books and records of the Company 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 Company’s compliance
with specified requirements.
In our
opinion, management’s assertion that MACC Private Equities Inc. complied with
the requirements of subsections (b) and (c) of rule 17f-2 of the Investment
Company Act of 1940 as of September 30, 2009 with respect to securities
reflected in the investment account of the Company 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 MACC Private Equities Inc. and the Securities and Exchange
Commission, and is not intended to be and should not be used by anyone other
than these specified parties.
/s/ KPMG
LLP
San
Diego, California
October
23, 2009