-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, LoL5b72IidbsRo89eNiJQ9zO7bsQhD8JD9bXvYr1lvXhYNqRNXBDPNRvMqrOAyML jPlJD/S96p5cJCSxkU8CqQ== 0001035449-09-000706.txt : 20091125 0001035449-09-000706.hdr.sgml : 20091125 20091125151235 ACCESSION NUMBER: 0001035449-09-000706 CONFORMED SUBMISSION TYPE: N-Q PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20090930 FILED AS OF DATE: 20091125 DATE AS OF CHANGE: 20091125 EFFECTIVENESS DATE: 20091125 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BRUCE FUND INC CENTRAL INDEX KEY: 0000047071 IRS NUMBER: 066104682 STATE OF INCORPORATION: MD FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: N-Q SEC ACT: 1940 Act SEC FILE NUMBER: 811-01528 FILM NUMBER: 091208217 BUSINESS ADDRESS: STREET 1: 20 N WACKER DR STREET 2: STE 2414 CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 3122369160 MAIL ADDRESS: STREET 1: 20 N WACKER DR STREET 2: STE 2414 CITY: CHICAGO STATE: IL ZIP: 60606 FORMER COMPANY: FORMER CONFORMED NAME: HEROLD FUND INC DATE OF NAME CHANGE: 19831114 0000047071 S000011411 BRUCE FUND C000031584 BRUCE FUND N-Q 1 bruce.htm BRUCE 1ST QRT NQ

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, DC 20549

 

QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED

MANAGEMENT INVESTMENT COMPANY

 

 

Investment Company Act file number

811-1528

 

 

Bruce Fund, Inc.

   (Exact name of registrant as specified in charter)

 

 

Bruce Fund, Inc.

20 N. Wacker Drive, Suite 2414

Chicago, IL

60606

 

(Address of principal executive offices)

(Zip code)

 

William J Murphy.

Unified Fund Services, Inc.

2960 N. Meridian Street, Ste. 300

 

Indianapolis, IN 46208

(Name and address of agent for service)

 

 

Registrant's telephone number, including area code:

317-917-7000

 

 

Date of fiscal year end:

6/30

 

 

Date of reporting period:

09/30/09

 

 

Form N-Q is to be used by management investment companies, other than small business investment companies registered on Form N-5 (§§ 239.24 and 274.5 of this chapter), to file reports with the Commission, not later than 60 days after the close of the first and third fiscal quarters, pursuant to rule 30b1-5 under the Investment Company Act of 1940 (17 CFR 270.30b1-5). The Commission may use the information provided on Form N-Q in its regulatory, disclosure review, inspection, and policymaking roles.

 

A registrant is required to disclose the information specified by Form N-Q, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained in Form N-Q unless the Form displays a currently valid Office of Management and Budget (“OMB”) control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to the Secretary, Securities and Exchange Commission, 450 Fifth Street, NW, Washington, DC 20549-0609. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.

 

Item 1. Schedule of Investments.

 


BRUCE FUND, INC.

SCHEDULE OF INVESTMENTS

September 30, 2009

(Unaudited)

COMMON STOCKS - (36.90%)

No. of Shares

Issue

Cost

Market Value

Automotive/Transportation (2.62%)

122,500

(a)

AMERCO

$ 7,194,045

$ 5,617,850

Biological Products (0.01%)

107,410

(a)

Advanced Life Sciences Holdings, Inc.

111,209

31,149

Business Services (0.51%)

130,000

(a)

Internet Capital Group, Inc.

1,016,211

1,086,800

Chemicals (1.40%)

620,270

(a)

Omega Protein Corp.

3,248,609

3,008,310

Consumer Products (4.41%)

1,663,656

(a)

Alanco Technologies, Inc.

3,609,525

931,647

313,900

(a)

American Italian Pasta Co. - Class A

1,302,443

8,531,802

4,911,968

9,463,449

Electric Services (2.27%)

294,849

(a)

Calpine Corp.

3,720,342

3,396,660

20,000

Integrys Energy Group, Inc.

463,954

717,800

50,000

Pepco Holdings, Inc.

554,830

744,000

4,739,126

4,858,460

Energy/Energy Services (3.85%)

80,000

(a)

Arena Resources, Inc.

709,600

2,840,000

238,500

(a)

ATP Oil & Gas Corp.

9,589,070

4,266,765

156,919

(a)

Double Eagle Petroleum Co.

3,182,328

750,073

80,000

(a)

Hercules Offshore, Inc.

2,461,778

392,800

15,942,776

8,249,638

Guided Missiles & Space Vehicles & Parts (1.47%)

1,120,073

(a)

Astrotech Corp.

3,626,083

3,158,606

Health Services (6.30%)

597,347

America Service Group, Inc.

6,866,334

9,880,119

681,934

(a)

EDAP TMS S.A. (ADR)

5,241,682

2,727,736

182,300

(a)

Health Grades, Inc.

156,028

902,385

12,264,044

13,510,240

Manufacturing (3.89%)

1,581,500

AirBoss of America Corp. (Canadian)

5,441,626

6,999,086

150,000

Tital International, Inc.

1,358,440

1,335,000

6,800,066

8,334,086

Mineral Exploration (3.21%)

5,825,100

(a)

Admiral Bay Resources, Inc.

4,153,315

408,054

280,000

Kinross Gold Corp.

2,749,745

6,076,000

199,270

(a)

Solitario Exploration & Royalty Corp. (Canadian)

347,555

392,562

7,250,615

6,876,616

Pharmaceutical/Drug Delivery (3.85%)

1,029,412

(a)

Cell Genesys, Inc.

575,783

358,235

766,053

(a)

Cell Therapeutics, Inc.

1,008,279

942,245

631,746

(a)

Durect Corp.

2,244,259

1,686,762

130,000

(a)

Elan Corp., plc (ADR)

851,573

924,300

302,300

(a)

EPIX Pharmaceuticals, Inc.

464,102

4,232

50,000

Merck & Co., Inc.

2,130,679

1,581,500

1,668,415

(a)

NexMed, Inc.

1,785,136

283,631

150,000

Pfizer, Inc.

3,890,679

2,482,500

12,950,490

8,263,405

*See accompanying notes which are an integral part of these financial statements.


 

BRUCE FUND, INC.

SCHEDULE OF INVESTMENTS - continued

September 30, 2009

(Unaudited)

COMMON STOCKS - (36.90%) - continued

No. of Shares

Issue

Cost

Market Value

Property-Casualty Insurance (2.48%)

211,502

(a)

GAINSCO, Inc.

$ 5,685,629

$ 2,944,108

45,000

RLI Corp.

2,225,358

2,375,100

7,910,987

5,319,208

Telecommunications (0.63%)

632,679

(a)

iBasis, Inc.

1,262,819

1,341,279

Total Common Stocks

89,229,048

79,119,096

CONVERTIBLE PREFERRED/PREFERRED STOCKS (1.19%)

Convertible Preferred Stocks (0.31)

10,000

AES Trust III 6.75%

331,030

443,125

129,900

Edge Petroleum Corp. - Series A, 5.75%

6,340,213

227,325

6,671,243

670,450

Preferred Stocks (0.88%)

80,000

AMERCO Series A, 8.50%

1,491,145

1,874,400

Total Convertible Preferred/Preferred Stocks

8,162,388

2,544,850

BONDS - (51.68%)

Principal

Issue

U.S. Government (15.58%)

$ 30,000,000

U.S. Treasury "Strips", 0.00% due 8-15-2028

11,649,385

13,578,060

30,000,000

U.S. Treasury "Strips", 0.00% due 8-15-2029

11,727,982

13,009,380

20,000,000

U.S. Treasury "Strips", 0.00% due 2-15-2036

5,989,958

6,806,720

29,367,325

33,394,160

Municipal (0.01%)

1,000,000

(a)

Indianapolis Airport Authority 6.50% due 11-15-2031

166,972

25,000

Corporate (13.87%)

2,300,000

(b)

Charter Communications, LLC 9.92% due 4-1-2011

1,881,438

17,250

4,000,000

Constellation Energy Group 7.60% due 4-1-2032

3,505,646

4,305,972

6,000,000

Energy XXI Gulf Coast, Inc. 10.00% due 6-15-2013

3,028,911

4,890,000

1,500,000

(c)

Land O' Lakes Capital Trust I 7.45% due 3-15-2028

965,145

1,312,500

3,000,000

McMoRan Exploration Co. 11.875% due 11-15-2014

2,292,360

3,015,000

5,000,000

Mirant Americas Gen, 11.875% due 05-01-2031

3,702,693

4,200,000

1,000,000

ONEOK, Inc. 6.00% due 6-15-2035

737,675

990,329

2,000,000

(c)

W & T Offshore, Inc. 8.25% due 6-15-2014

1,444,734

1,830,000

2,000,000

Whiting Petroleum Corp., 7.00%, due 2-01-2014

1,410,023

1,985,000

7,300,000

(c)

XM Satellite Radio, Inc. 13.00% due 8-1-2013

2,828,387

7,190,500

21,797,012

29,736,551

Corporate Convertibles (22.22%)

10,179,000

(e)

Antigenics, Inc. 5.25% due 2-1-2025

6,066,998

6,616,350

9,462,117

(b)

Atherogenics, Inc. 4.50% due 3-1-2011

6,082,843

946

4,389,000

(c)

C&D Technologies, Inc. 5.25% due 11-1-2025

3,933,073

2,830,905

2,250,000

C&D Technologies, Inc. 5.25% due 11-1-2025

2,178,239

1,451,250

2,570,000

(e)

C&D Technologies, Inc. 5.50% due 11-15-2026

1,679,813

1,843,975

1,000,000

Cell Genesys, Inc. 3.125% due 11-1-2011

893,636

565,000

1,550,000

(e)

Cell Genesys, Inc. 3.125% due 5-1-2013

1,392,396

744,000

2,500,000

Cell Therapeutics, Inc. 4.00% due 7-1-2010

2,223,971

2,175,000

5,250,000

(c)(e)

Cell Therapeutics, Inc. 5.75% due 12-15-2011

4,893,068

4,252,500

1,800,000

(b)(c)(e)

Ciphergen Biosystems, Inc. 7.00% due 9-1-2011

1,567,679

1,251,000

14,887,000

(b)

deCODE Genetics, Inc. 3.50% due 4-15-2011

8,568,352

2,270,268

2,000,000

(c)(e)

EDAP TMS S.A. 9.00% due 10-30-2012

2,000,000

1,800,000

6,600,000

Endeavor International Corp. 6.00% due 1-15-2012

6,323,247

4,950,000

3,000,000

Flotek Industries, Inc. 5.25% due 2-15-2028

794,180

1,500,000

1,000,000

Human Genome Sciences, Inc. 2.25% due 10-15-2011

945,836

1,388,750

2,150,000

Incyte Corp. 3.50% due 2-15-2011

2,009,421

2,107,000

3,000,000

(c)

Isis Pharmaceuticals, Inc. 2.625% due 2-15-2027

2,768,176

3,536,250

60,000

Isis Pharmaceuticals, Inc. 2.625% due 2-15-2027

62,233

70,725

5,000,000

Mankind Corp. 3.75% due 12-15-2013

2,862,903

3,862,500

2,700,000

(b)(e)

Midway Games, Inc. 6.00% due 9-30-2025

2,532,792

540,000

1,762,892

(e)

Oscient Pharmaceuticals 12.50% due 1-15-2011

3,125,929

88,145

7,000,000

(c)

Vion Pharmaceuticals, Inc. 7.75% due 2-15-2012

6,767,471

1,785,000

1,920,000

Vion Pharmaceuticals, Inc. 7.75% due 2-15-2012

973,216

489,600

2,000,000

ViroPharma, Inc. 2.00% due 3-15-2017

1,563,357

1,530,000

72,208,829

47,649,164

Total Bonds

123,540,138

110,804,875

*See accompanying notes which are an integral part of these financial statements.


 

BRUCE FUND, INC.

SCHEDULE OF INVESTMENTS - continued

September 30, 2009

(Unaudited)

WARRANTS - (0.06%)

No. of Shares

Issue

Cost

Market Value

168,000

(a)(e)

EDAP, Inc., expires 10-30-2013

$ -

$ 126,000

468,000

(a)(e)

Vion Pharmaceuticals, Inc., expires 2-15-2010

-

4,680

Total Warrants

-

130,680

RIGHTS - (0.01%)

200,000

(a)(e)(f)

Calpine Corp. Escrow Retirement Rights

-

20,000

3,500

(a)(e)(f)

Epix Pharmacuticals CVR

-

-

Total Rights

-

20,000

MONEY MARKET - (9.03%)

19,364,283

(d)

Fidelity Institutional Money Market Treasury Only - Class I, 0.08%

19,364,283

19,364,283

Total Money Market

19,364,283

19,364,283

Total Investments (98.87%)

$ 240,295,857

$ 211,983,784

Other assets less liabilities (1.13%)

2,415,383

TOTAL NET ASSETS (100.00%)

$ 214,399,167

(a)

Non-cash income producing security.

(b)

In default.

(c)

Private Placement and restricted security under Rule 144A of the Securities Act of 1933.

(d)

Variable rate securities; the money market rate shown represents the rate at September 30, 2009.

(e)

This security is currently valued according to the fair value procedures approved by the Board of Directors.

(f)

This security has no expiration date, it will convert to common stock at a future date.

Tax Related

Gross unrealized appreciation

$ 37,075,739

Gross unrealized depreciation

(65,387,812)

Net unrealized depreciation

$ (28,312,073)

Aggregate cost of securities for income tax purposes

$ 240,295,857

*See accompanying notes which are an integral part of these financial statements.


Bruce Fund

Related Footnotes to the Schedule of Investments

September 30, 2009 – (Unaudited)

 

Securities Valuations – All investments in securities are recorded at their estimated fair value as described below.

Fair value is defined as the price that a Fund would receive upon selling an investment in a timely transaction to an independent buyer in the principal or most advantageous market of the investment. GAAP establishes a three-tier hierarchy to maximize the use of observable market data and minimize the use of unobservable inputs and to establish classification of fair value measurements for disclosure purposes.

 

Inputs refer broadly to the assumptions that market participants would use in pricing the asset or liability, including assumptions about risk, for example, the risk inherent in a particular valuation technique used to measure fair value including such a pricing model and/or the risk inherent in the inputs to the valuation technique. Inputs may be observable or unobservable. Observable inputs are inputs that reflect the assumptions market participants would use in pricing the asset or liability developed based on market data obtained from sources independent of the reporting entity. Unobservable inputs are inputs that reflect the reporting entity’s own assumptions about the assumptions market participants would use in pricing the asset or liability developed based on the best information available in the circumstances.

 

Various inputs are used in determining the value of the Fund’s investments. These inputs are summarized in the three broad levels listed below.

 

Level 1 – quoted prices in active markets for identical securities

 

Level 2 – other significant observable inputs (including, but not limited to, quoted prices for an identical security in an inactive market, quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.)

 

Level 3 – significant unobservable inputs (including the Fund’s own assumptions in determining fair value of investments based on the best information available)

The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety, is determined based on the lowest level input that is significant to the fair value measurement in its entirety.

 

Equity securities, including common stock, convertible preferred and preferred stocks, warrants, rights, are generally valued by using market quotations, but may be valued on the basis of prices furnished by a pricing service when the Advisor believes such prices more accurately reflect the fair value of such securities. Securities that are traded on any stock exchange are generally valued by the pricing service at the last quoted sale price. Lacking a last sale price, an exchange traded security is generally valued by the pricing service at its last bid price. Securities traded in the NASDAQ over-the-counter market are generally valued by the pricing service at the NASDAQ Official Closing Price. When using the market quotations or close prices provided by the pricing service and when the market is considered active, the security will be classified as a Level 1 security. Sometimes, an equity security owned by the Funds will be valued by the pricing service with factors other than market quotations or when the market is considered inactive. When this happens, the security will be classified as a Level 2 security. When market quotations are not readily available, when the Advisor determines that the market quotation or the price provided by the pricing service does not accurately reflect the current fair value, or when restricted or illiquid securities are being valued, such securities are valued as determined in good faith by the Advisor, in conformity with guidelines adopted by and subject to review by the Board. These securities will be categorized as Level 3 securities.

Investments in mutual funds, including money market mutual funds, are generally priced at the ending net asset value (NAV) provided by the service agent of the funds. These securities will be categorized as Level 1 securities.

Fixed income securities such as corporate bonds, convertible corporate bonds, municipal bonds, and U.S. government securities, when valued using market quotations in an active market, will be categorized as Level 1 securities. However, they may be valued on the basis of prices furnished by a pricing service when the Advisor believes such prices more accurately reflect the fair value of such securities. A pricing service utilizes electronic data processing techniques based on yield spreads relating to securities with similar characteristics to determine prices for normal institutional-size trading units of debt securities without regard to sale or bid prices. These securities will generally be categorized as Level 2 securities. If the Advisor decides that a price provided by the pricing service does not accurately reflect the fair value of the securities, when prices are not readily available from a pricing service, or when restricted or illiquid securities are being valued, securities are valued at fair value as determined in good faith by the Advisor, in conformity with guidelines adopted by and subject to review of the Board. These securities will be categorized as Level 3 securities. The ability of issuers of debt securities held by the Fund to meet their obligations may be affected by economic and political developments in a specific country or region.

 


Bruce Fund

Related Footnotes to the Schedule of Investments - continued

September 30, 2009 – (Unaudited)

 

Short-term investments in fixed income securities, (those with maturities of less than 60 days when acquired, or which subsequently are within 60 days of maturity), are valued by using the amortized cost method of valuation, which the Board has determined will represent fair value. These securities will be classified as Level 2 securities.

 

In accordance with the Trust’s good faith pricing guidelines, the Advisor is required to consider all appropriate factors relevant to the value of securities for which it has determined other pricing sources are not available or reliable as described above. No single standard exists for determining fair value, because fair value depends upon the circumstances of each individual case. As a general principle, the current fair value of an issue of securities being valued by the Advisor would appear to be the amount which the owner might reasonably expect to receive for them upon their current sale. Methods which are in accordance with this principle may, for example, be based on (i) a multiple of earnings; (ii) a discount from market of a similar freely traded security (including a derivative security or a basket of securities traded on other markets, exchanges or among dealers); or (iii) yield to maturity with respect to debt issues, or a combination of these and other methods. Good faith pricing is permitted if, in the Advisor’s opinion, the validity of market quotations appears to be questionable based on factors such as evidence of a thin market in the security based on a small number of quotations, a significant event occurs after the close of a market but before a Fund’s NAV calculation that may affect a security’s value, or the Advisor is aware of any other data that calls into question the reliability of market quotations. Good faith pricing may also be used in instances when the bonds the Funds invest in may default or otherwise cease to have market quotations readily available.

 

The following is a summary of the inputs used to value the Fund’s investments as of September 30, 2009:

 

 

Valuation Inputs

 

 

Investments

Level 1 - Quoted Prices in Active Markets

Level 2 - Other Significant Observable Inputs

Level 3 - Significant Unobservable Inputs

Total

 

 

 

 

 

Common Stocks*

$ 79,119,096

$ -

$ -

$ 79,119,096

 

Preferred Securities

2,544,850

-

-

2,544,850

 

Corporate Bonds

-

29,736,551

29,736,551

 

Corporate Convertible Bonds

-

30,513,194

17,135,970

47,649,164

 

Municiple Bonds

-

25,000

-

25,000

 

US Government Bonds

-

33,394,160

-

33,394,160

 

Warrants

-

-

130,680

130,680

 

Rights

-

-

20,000

20,000

 

Money Market Securities

19,364,283

-

-

19,364,283

 

Total

$ 101,028,229

$ 93,668,905

$ 17,286,650

$ 211,983,784

*Refer to the Schedule of Investments for industry classifications.

 


Following is a reconciliation of investments in which significant unobservable inputs (Level 3) were used in determining fair value for the Income Fund:

 

 

Balance as of June 30, 2009

Realized gain (loss)

(Amortization) / Accretion

Change in unrealized appreciation (depreciation)

Net purchases (sales)

Transfers in and/or out of Level 3

Balance as of September 30, 2009

 

 

 

 

 

 

 

 

Corporate Convertible Bonds

$ 14,835,785

$ (136,600)

$ 64,092

$ 1,803,943

$ 568,750

$ -

$ 17,135,970

 

Warrants

46,680

-

-

84,000

-

-

130,680

 

Rights

20,000

-

-

-

-

-

20,000

 

Total

$ 14,902,465

$ (136,600)

$ 64,092

$ 1,887,943

$ 568,750

$ -

$ 17,286,650

 

 

The total change in unrealized appreciation (depreciation) attributable to Level 3 investments still held at September 30, 2009 was $1,215,240.

 

 

Total Change in Unrealized Appreciation (Depreciation)

 

 

Corporate Convertible Bonds

$ 1,131,240

 

 

Warrants

84,000

 

 

Total

$ 1,215,240

 

 


Item 2. Controls and Procedures.

 

(a)        Based on an evaluation of the registrant’s disclosure controls and procedures as of November 20, 2009 the disclosure controls and procedures are reasonably designed to ensure that the information required in filings on Forms N-Q is recorded, processed, summarized, and reported on a timely basis.

 

(b)        There were no significant changes in the registrant’s internal control over financial reporting that occurred during the registrant’s last fiscal quarter that have materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.

 

 

Item 3. Exhibits.

 

Certifications by the registrant's principal executive officer and principal financial officer, pursuant to the Sarbanes- Oxley Act of 2002 and required by Rule 30a-2a under the Investment Company Act of 1940 are filed herewith.

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

Registrant_____Bruce Fund, Inc._______________

 

By

___/s/ Robert B. Bruce ________

 

Robert B. Bruce, President

 

Date___11/24/09______________

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

 

 

By

/s/ Robert B. Bruce _

 

Robert B. Bruce, President

 

Date__11/24/09_______________

 

 

By

/s/ R. Jeffery Bruce _____

R. Jeffery Bruce, Principal Accounting Officer

 

Date___11/24/09_____________

 

.

 

 

EX-99.CERT 2 cert99.htm CERT 99

FORM N-Q CERTIFICATION
 

I, Robert B. Bruce, certify that:
 
    1.      I have reviewed this report on Form N-Q of Bruce Fund;
 

2.      Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.      Based on my knowledge, the schedules of investments included in this report fairly present in all material respects the investments of the registrant as of the end of the fiscal quarter for which the report is filed;

4.      The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a)     designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b)     designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c)     evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

d)     disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.      The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

Date: _11/24/09                                                                                  /s/ Robert B. Bruce               

Robert B. Bruce

President


 

FORM N-Q CERTIFICATION
 

I, R. Jeffery Bruce, certify that:
 
    1.      I have reviewed this report on Form N-Q of Bruce Fund;
 

2.      Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.      Based on my knowledge, the schedules of investments included in this report fairly present in all material respects the investments of the registrant as of the end of the fiscal quarter for which the report is filed;

4.      The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a)     designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b)     designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c)     evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

d)     disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.      The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

Date:      11/24/09                                                             /s/ R. Jeffery Bruce          

R. Jeffery Bruce

Principal Accounting Officer

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