SEC Count Letter
Report of Independent Registered Public Accounting Firm
The Board of Directors
MACC Private Equities Inc. and subsidiary
and
The Securities and Exchange Commission:
We have examined management's assertion, included in the accompanying Management
Assertion Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, that MACC Private Equities Inc. and subsidiary (the Company)
complied with the requirements of subsections (b) and (c) of Rule 17f-2 under
the Investment Company Act of 1940 (the Act) as of August 6, 2007. 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 August 6, 2007, and with respect to agreement of security
purchases and sales, for the period May 2, 2007 (the date of our last
examination), through August 6, 2007:
Count and inspection of all securities located in the vault of US Bank in
Cedar Rapids, Iowa
Reconciliation of all such securities to the books and records of the
Company
Confirmation of selected security transactions since the date of our last
report
Vouching of proceeds from certain sales transactions since the date of our
last report
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. and
subsidiary complied with the requirements of subsections (b) and (c) of rule
17f-2 of the Investment Company Act of 1940 as of August 6, 2007 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 subsidiary 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
Des Moines, Iowa
August 20, 2007
MACC PRIVATE EQUITIES INC.
August 6, 2007
KPMG LLP
2500 Ruan Center
Des Moines, IA 50309
Ladies and Gentlemen:
RE: Management Assertion Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
MACC Private Equities Inc. is 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. It is
also responsible for establishing and maintaining an effective internal control
structure over compliance with Rule 17f-2 requirements.
MACC Private Equities Inc. has performed an evaluation of its compliance with
the requirements of subsections (b) and (c) of Rule 17f-2 as of August 6, 2007
for the period May 2, 2007 through August 6, 2007. Based on this evaluation, it
has determined that MACC Private Equities Inc. was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of August 6, 2007, with respect to securities reflected in the
investment accounts of MACC Private Equities Inc. with the following exception:
A warrant included in the schedule of investments for one portfolio
company was not located in the vault. The warrant was misplaced during
delivery of the certificate. MACC is planning on waiting until the
warrant is exercised to carry out the legal proceedings to replace the
warrant. This warrant has a cost and valuation of $0.
Very truly yours,
MACC PRIVATE EQUITIES INC.
By: /s/ David R. Schroder
David R. Schroder, President
/s/ Marilyn Benge
Marilyn Benge, Controller
101 Second Street SE, Suite 800-Cedar Rapids, Iowa 52401-(319 363-8249-(319) 363-9683 Fax