0001162044-22-000307.txt : 20220309 0001162044-22-000307.hdr.sgml : 20220309 20220309151021 ACCESSION NUMBER: 0001162044-22-000307 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20211231 FILED AS OF DATE: 20220309 DATE AS OF CHANGE: 20220309 EFFECTIVENESS DATE: 20220309 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BERTOLET CAPITAL TRUST CENTRAL INDEX KEY: 0001216907 IRS NUMBER: 061680405 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-21291 FILM NUMBER: 22725157 BUSINESS ADDRESS: STREET 1: 745 FIFTH AVE STREET 2: STE 2400 CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 212 605 7100 MAIL ADDRESS: STREET 1: 745 FIFTH AVE STREET 2: STE 2400 CITY: NEW YORK STATE: NY ZIP: 10151 0001216907 S000004888 Pinnacle Value Fund C000013242 Pinnacle Value Fund PVFIX N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001216907 XXXXXXXX false false false N-1A S000004888 C000013242 BERTOLET CAPITAL TRUST 811-21291 0001216907 549300VIVOKDUEPFO698 745 Fifth Ave, Suite 2400 New York 10151 US-NY US 212-605-7100 Bertolet Capital Trust 745 Fifth Ave, Suite 2400 New York 10151 212-605-7100 All accounts, books and documents required to be maintained by the Registrant pursuant to Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 through 31a-3 thereunder are maintained at the office of the Registrant except all those relating to the activities of the Fund's Custodian, Transfer Agent and Shareholder Servicing Agent. Mutual Shareholder Services, LLC 8000 Town Centre Drive, Suite 400 Broadview Heights 44147 440-922-0066 All accounts, books and documents required to be maintained by the Transfer Agent, Fund Accounting Agent and Shareholder Servicing Agent pursuant to Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 through 31a-3. U.S. Bank, N.A. 425 Walnut Street Cincinnati 45202 513-632-4140 All accounts, books and documents relating to the activities of the Fund's Custodian. Bertolet Capital, LLC 745 Fifth Ave, Suite 2400 New York 10151 212-605-7100 Maintains records relating to its function as the investment adviser to the Fund. N N N N-1A 1 Y John E. Deysher N/A Y Edward P. Breau N/A N Richard M. Connelly N/A N James W. Denney N/A N John E. Deysher N/A 745 Fifth Ave, Suite 2400 New York 10151 XXXXXX N N N N N N N N Tait, Weller & Baker, LLP 445 N/A N N N N N N N Pinnacle Value Fund S000004888 549300HGOX2RHMDP5044 N 1 0 0 N/A N N N N N/A N/A N/A N/A Y Y Y N Bertolet Capital, LLC 801-61782 000125121 N/A N Mutual Shareholder Services, LLC 084-05821 N/A N N N FIS MARKETMAP ANALYTIC PLATFORM N/A N N U.S. Bank, N.A. 5493001WC5CQQI9L9G80 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Mutual Shareholder Services, LLC N/A N N N Bertolet Capital, LLC N/A Y N N Wells Fargo Clearing Services, LLC 008-37180 000019616 88KRVSOEKUGQZJ3DKW55 2205.84 CANTOR FITZGERALD & CO. 008-00201 000000134 5493004J7H4GCPG6OB62 3197.53 Virtu ITG, LLC 008-44218 000029299 549300S41SMIODVIT266 5458.86 Canaccord Genuity, LLC 008-03271 000001020 WTX5X269IUOQ9YMI7R44 5240.13 16102.36 0 N 32956858.85 N N N N false false true false false false INTERNAL CONTROL RPT 2 pinnaclevaluefundncen123121.htm Audit Committee Meeting



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


Shareholders and Board of Trustees

Bertolet Capital Trust

New York, New York


In planning and performing our audit of the financial statements of Pinnacle Value Fund, a series of shares of Bertolet Capital Trust, as of and for the year ended December 31, 2021, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered its internal control over financial reporting, including control activities for safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting.  Accordingly, we express no such opinion.


The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A company’s internal control over financial reporting is a process designed 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.  A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company’s assets that could have a material effect on the financial statements.


Because of inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.


A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company’s annual or interim financial statements will not be prevented or detected on a timely basis.


Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States).  However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of December 31, 2021.


This report is intended solely for the information and use of management, Shareholders and Board of Trustees of Bertolet Capital Trust 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/ TAIT, WELLER & BAKER LLP


TAIT, WELLER & BAKER LLP

Philadelphia, Pennsylvania

February 28, 2022