SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C.  20549
              ____________________________________________________

                                    FORM 8-K
                                 CURRENT REPORT
          Pursuant to Section 13 or 15(d) of the Securities Exchange Act
                                    of 1934

                               December 27, 2004
                Date of Report (Date of earliest event reported)
             ____________________________________________________

                            BRONCO ENERGY FUND, INC.
            (Exact name of registrant as specified in its charter)

                                    Nevada
         (State or other jurisdiction of incorporation or organization)

                                  814-00690
                             (Commission File No.)

                                 86-0972709
                     (IRS Employer Identification Number)

          2920 N. Swan Suite 206, Tucson AZ 		  85712
       (Address of principal executive offices)       (Zip Code)

                               (866) 305-1755
                  (Telephone number, including area code

Check the appropriate box below if the Form 8-K filing is intended to
simultaneously satisfy the filing obligation of the registrant under any of
the following provisions (see General Instruction A.2. below):


{ } Written communications pursuant to Rule 425 under the Securities Act
    (17 CFR 230.425)

[ ] Soliciting material pursuant to Rule 14a-12 under the Securities
	Exchange Act (17 CFR 240.14a-12)

[ ] Pre-commencement communications pursuant to Rule 14d-2(b) under the
       Exchange Act (17 CFR 240.14d-2(b))

[ ] Pre-commencement communications pursuant to Rule 13e-4(c) under the
         Exchange Act (17 CFR 240.13e-4(c))

       _____________________________________________________________





Section 8  OTHER EVENTS

Item 8.01. Other Events.   Bronco Energy Fund, Inc. (the
Company), is a publicly traded Nevada corporation formed in June
1997 with its principal offices and operations center in Tucson,
Arizona. The Company has recently filed a notification under Form
N54a with the U.S. Securities and Exchange Commission, (the SEC)
indicating its election to be regulated as a business development
company under the Investment Company Act of 1940 (the ?1940 Act?).
In connection with this election, the Company has adopted
corporate resolutions and intends to operate as a closed-end
management investment company as such a business development
company (a BDC).  We disclose the following information which is
a material departure from our prior business plan.

INVESTMENT STRATEGY

We have conducted limited operations to date. Under this recent
election, we have been organized to provide investors with the
opportunity to participate, with a modest amount in venture
capital, in investments that are generally not available to the
public and that typically require substantially larger financial
commitments. In addition, we will provide professional
management and administration that might otherwise be
unavailable to investors if they were to engage directly in
venture capital investing.  We have decided to be regulated as a
business development company under the 1940 Act, and will
operate as a non-diversified company as that term is defined in
Section 5(b)(2) of the 1940 Act.  We will, at all times, conduct
our business so as to retain our status as a BDC.   We may not
change the nature of our business so as to cease to be, or
withdraw our election as, a BDC without the approval of the
holders of a majority of our outstanding voting stock as defined
under the 1940 Act.

As a business development company, we are required to invest at
least 70% of our total assets in qualifying assets, which,
generally, are securities of private companies or securities of
public companies whose securities are not eligible for purchase
on margin (which includes many companies with thinly traded
securities that are quoted in the pink sheets or the NASD
Electronic Quotation Service.)   We must also offer to provide
significant managerial assistance to these portfolio companies.
Qualifying assets may also include:

*	cash,
*	cash equivalents,
*	U.S. Government securities, or
*	high-quality debt investments maturing in one year or less
from the date of investment.

We may invest a portion of the remaining 30% of our total assets
in debt and/or equity securities of companies that may be larger
or more stabilized than target portfolio companies.

Nature of a BDC

The 1940 Act defines a BDC as a closed-end management investment
company that provides small businesses that qualify as an
eligible portfolio company with investment capital and also
significant managerial assistance.  A BDC is required under the
1940 Act to invest at least 70% of its total assets in
qualifying assets consisting of eligible portfolio companies as
defined in the 1940 Act and certain other assets including cash
and cash equivalents.

An eligible portfolio company generally is a United States
company that is not an investment company and that:

*	does not have a class of securities registered on an
exchange or included in the Federal Reserve Board's over-
the-counter margin list;
*	is actively controlled by a BDC and has an affiliate of a
BDC on its board of directors; or
*	meets such other criteria as may be established by the SEC.

Control under the 1940 Act is presumed to exist where a BDC owns
more than 25% of the outstanding voting securities of the
eligible portfolio company.  We may or may not control our
portfolio companies.
An example of an eligible portfolio company is a new start up
company or a privately owned company that has not yet gone
public by selling its shares in the open market and has not
applied for having its shares listed on a nationally recognized
exchange such as the NYSE the American Stock Exchange, National
Association of Securities Dealers' Automated Quotation System,
or the National Market System.  An eligible portfolio company
can also be one which is subject to filing, has filed, or has
recently emerged from reorganization protection under Chapter 11
of the Bankruptcy Act.

A BDC may invest the remaining 30% of its total assets in non-
qualifying assets, including companies that are not eligible
portfolio companies.  The foregoing percentages will be
determined, in the case of financings in which a BDC commits to
provide financing prior to funding the commitment, by the amount
of the BDC's total assets represented by the value of the
maximum amount of securities to be issued by the borrower or
lessee to the BDC pursuant to such commitment.   As a BDC, we
must invest at least 70% of our total assets in qualifying
assets but may invest more in such qualifying assets.


Primary Strategy

We will have significant relative flexibility in selecting and
structuring our investments.  We will not be subject to many of
the regulatory limitations that govern traditional lending
institutions such as banks.   We will seek to structure our
investments so as to take into account the uncertain and
potentially variable financial performance of our portfolio
companies.   This should enable our portfolio companies to
retain access to committed capital at different stages in their
development and eliminate some of the uncertainty surrounding
their capital allocation decisions.   We will calculate rates of
return on invested capital based on a combination of up-front
commitment fees, current and deferred interest rates and
residual values, which may take the form of common stock,
warrants, equity appreciation rights or future contract
payments.   We believe that this flexible approach to
structuring investments will facilitate positive, long-term
relationships with our portfolio companies and enable us to
become a preferred source of capital to them.   We also believe
our approach should enable debt financing to develop into a
viable alternative capital source for funding the growth of
target companies that wish to avoid the dilutive effects of
equity financings for existing equity holders.

Longer Investment Horizon - We will not be subject to periodic
capital return requirements.   These requirements, which are
standard for most private equity and venture capital funds,
typically require that these funds return to investors the
initial capital investment after a pre-agreed time, together
with any capital gains on such capital investment.   These
provisions often force such funds to seek the return of their
investments in portfolio companies through mergers, public
equity offerings or other liquidity events more quickly than
they otherwise might, which can result in a lower overall return
to investors and adversely affect the ultimate viability of the
affected portfolio companies.  Because we may invest in the same
portfolio companies as these funds, we are subject to these
risks if these funds demand a return on their investments in the
portfolio companies.  We believe that our flexibility to take a
longer-term view should help us to maximize returns on our
invested capital while still meeting the needs of our portfolio
companies.

Established Deal Sourcing Network - We believe that, through our
management and directors, we have solid contacts and sources
from which to generate investment opportunities. These contacts
and sources include:

*	public and private companies,
*	investment bankers,
*	attorneys,
*	accountants,
*	consultants, and
*	commercial bankers.

However, we cannot assure you that such relationships will lead
to the origination of debt or other investments.

Investment Criteria

As a matter of policy, we will not purchase or sell real estate
or interests in real estate or real estate investment trusts
except that we may:

*	purchase and sell real estate or interests in real estate
in connection with the orderly liquidation of investments,
or in connection with foreclosure on collateral;
*	own the securities of companies that are in the business of
buying, selling or developing real estate; or
*	finance the purchase of real estate by our portfolio
companies.

We will limit our investments in more traditional securities
(stock and debt instruments) and will not, as a matter of
policy:

*	sell securities short except with regard to managing the
risks associated with publicly-traded securities issued by
our portfolio companies;
*	Purchase securities on margin (except to the extent that we
may purchase securities with borrowed money); or
*	engage in the purchase or sale of commodities or commodity
contracts, including futures contracts except where
necessary in working out distressed loan; or
*	investment situations or in hedging the risks associated
with interest rate fluctuations, and, in such cases, only
after all necessary registrations or exemptions from
registration with the Commodity Futures Trading Commission
have been obtained.

Prospective Portfolio Company Characteristics - We have
identified several criteria that we believe will prove important
in seeking our investment objective with respect to target
companies.   These criteria will provide general guidelines for
our investment decisions; however, we caution readers that not
all of these criteria will be met by each prospective portfolio
company in which we choose to invest.

Experienced Management - We will generally require that our
portfolio companies have an experienced president or management
team.   We will also require the portfolio companies to have in
place proper incentives to induce management to succeed and to
act in concert with our interests as investors, including having
significant equity interests.  We intend to provide assistance
in this area either supervising management or providing
management for our portfolio companies.

Products or Services - We will seek companies that are involved
in products or services that do not require significant
additional capital or research expenditures.  In general, we
will seek target companies that make innovative use of proven
technologies or methods.

Proprietary Advantage - We expect to favor companies that can
demonstrate some kind of proprietary sustainable advantage with
respect to their competition.  Proprietary advantages include,
but are not limited to:

*	patents or trade secrets with respect to owning or
manufacturing its products, and
*	a demonstrable and sustainable marketing advantage over its
competition

Marketing strategies impose unusual burdens on management to be
continuously ahead of its competition, either through some kind
of technological advantage or by being continuously more
creative than its competition.

Profitable or Nearly Profitable Operations Based on Cash Flow
from Operations - We will focus on target companies that are
profitable or nearly profitable on an operating cash flow basis.
Typically, we would not expect to invest in start-up companies
unless there is a clear exit strategy in place.

Potential for Future Growth - We will generally require that a
prospective target company, in addition to generating sufficient
cash flow to cover its operating costs and service its debt,
demonstrate an ability to increase its revenues and operating
cash flow over time.   The anticipated growth rate of a
prospective target company will be a key factor in determining
the value that we ascribe to any warrants or other equity
securities that we may acquire in connection with an investment
in debt securities.

Exit Strategy. Prior to making an investment in a portfolio
company, we will analyze the potential for that company to
increase the liquidity of its common equity through a future
event that would enable us to realize appreciation, if any, in
the value of our equity interest.   Liquidity events may
include:

*	an initial public offering,
*	a private sale of our equity interest to a third party,
*	a merger or an acquisition of the portfolio company, or
*	a purchase of our equity position by the portfolio company
      or one of its stockholders.

We may acquire warrants to purchase equity securities and/or
convertible preferred stock of the eligible portfolio companies
in connection with providing financing.   The terms of the
warrants, including the expiration date, exercise price and
terms of the equity security for which the warrant may be
exercised, will be negotiated individually with each eligible
portfolio company, and will likely be affected by the price and
terms of securities issued by the eligible portfolio company to
other venture capitalists and other holders.   We anticipate
that most warrants will be for a term of five to ten years, and
will have an exercise price based upon the price at which the
eligible portfolio company most recently issued equity
securities or, if a new equity offering is imminent, equity
securities.    The equity securities for which the warrant will
be exercised generally will be common stock of which there may
be one or more classes or convertible preferred stock.
Substantially all the warrants and underlying equity securities
will be restricted securities under the 1933 Act at the time of
the issuance.   We will generally negotiate for registration
rights with the issuer that may provide:

*	?piggyback" registration rights, which will permit us under
certain circumstances, to include some or all of the
securities owned by us in a registration statement filed by
the eligible portfolio company, or
*	in circumstances, "demand" registration rights permitting
us under certain circumstances, to require the eligible
portfolio company to register the securities under the 1933
Act, in some cases at our expense.   We will generally
negotiate net issuance provisions in the warrants, which
will allow us to receive upon exercise of the warrant
without payment of any cash a net amount of shares
determined by the increase in the value of the issuer's
stock above the exercise price stated in the warrant.

Liquidation Value of Assets - Although we do not intend to
operate as an asset-based lender, the prospective liquidation
value of the assets, if any, collateralizing any debt securities
that we hold will be an important factor in our credit analysis.
We will emphasize both tangible assets, such as:

*	accounts receivable,
*	inventory, and
*	equipment,

and intangible assets, such as:

*	intellectual property,
*	customer lists,
*	networks, and
*	databases.

Investment Process

Due Diligence - If a target company generally meets the
characteristics described above, we will perform initial due
diligence, including:
*	company and technology assessments,
*	existing management team,
*	market analysis,
*	competitive analysis,
*	evaluation of management, risk analysis and transaction
      size,
*	pricing, and
*	structure analysis.

Much of this work will be done by management and professionals
who are well known by management.  The criteria delineated above
provide general parameters for our investment decisions.  We
intend to pursue an investment strategy by further imposing such
criteria and reviews that best insures the value of our
investments.  As unique circumstances may arise or be uncovered,
not all of such criteria will be followed in each instance but
the process provides a guideline by which investments can be
prudently made and managed. Upon successful completion of the
preliminary evaluation, we will decide whether to deliver a non-
binding letter of intent and move forward towards the completion
of a transaction.

In our review of the management team, we look at the following:

*	Interviews with management and significant shareholders,
      including any financial or strategic sponsor;
*	Review of financing history;
*	Review of management's track record with respect to:
o	product development and marketing,
o	mergers and acquisitions,
o	alliances,
o	collaborations,
o	research and development outsourcing and other
      strategic activities;
*	Assessment of competition; and
*	Review of exit strategies.

In our review of the financial conditions, we look at the
following:

*	Evaluation of future financing needs and plans;
*	Detailed analysis of financial performance;
*	Development of pro forma financial projections; and
*	Review of assets and liabilities, including contingent
      Liabilities, if any, and legal and regulatory risks.

In our review of the products and services of the portfolio
company, we look at the following:

*	Evaluation of intellectual property position;
*	Review of existing customer or similar agreements and
      arrangements;
*	Analysis of core technology;
*	Assessment of collaborations;
*	Review of sales and marketing procedures; and
*	Assessment of market and growth potential.

Upon completion of these analyses, we will conduct on-site
visits with the target company's management team.   Also, in
cases in which a target company is at a mature stage of
development and if other matters that warrant such an
evaluation, we will obtain an independent appraisal of the
target company.

Ongoing Relationships with Portfolio Companies

Monitoring - We will continuously monitor our portfolio
companies in order to determine whether they are meeting our
financing criteria and their respective business plans.   We may
decline to make additional investments in portfolio companies
that do not continue to meet our financing criteria.   However,
we may choose to make additional investments in portfolio
companies that do not do so, but we believe that we will
nevertheless perform well in the future.

We will monitor the financial trends of each portfolio company
to assess the appropriate course of action for each company and
to evaluate overall portfolio quality.  Our management team and
consulting professionals, who are well known by our management
team, will closely monitor the status and performance of each
individual company on at least a quarterly and, in some cases, a
monthly basis.

We will use several methods of evaluating and monitoring the
performance and fair value of our debt and equity positions,
including but not limited to the following:

*	Assessment of business development success, including
      product development, financings, profitability and the
      portfolio company's overall adherence to its business plan;
*	Periodic and regular contact with portfolio company
      management to discuss financial position, requirements and
      accomplishments;
*	Periodic and regular formal update interviews with
      portfolio company management and, if appropriate, the
      financial or strategic sponsor;
*	Attendance at and participation in board meetings;
*	Review of monthly and quarterly financial statements and
      financial projections for portfolio companies.

Managerial Assistance - As a business development company, we
will offer, and in many cases may provide, significant
managerial assistance to our portfolio companies.   This
assistance will typically involve:

*	monitoring the operations of our portfolio companies,
*	participating in their board and management meetings,
*	consulting with and advising their officers, and
*	providing other organizational and financial guidance.


Diversification

As a BDC, we must invest at least 70% of our total assets in
qualifying assets consisting of investments in eligible
portfolio companies and certain other assets including cash and
cash equivalents.   In order to receive favorable pass-through
tax treatment on its distributions to our shareholders, we
intend to diversify our pool of investments in such a manner so
as to qualify as a diversified closed end management investment
company.   However, because of the limited size of the funding
which is likely to be available to us, we will likely be
classified as a non-diversified closed end investment company
under the 1940 Act.  Until we qualify as a registered investment
company, we will not be subject to the diversification
requirements applicable to RICs under the Internal Revenue Code.
Therefore, we will not receive favorable pass through tax
treatment on distributions to our shareholders.   In the future,
we will seek to increase the diversification of our portfolio so
as to make it possible to meet the RIC diversification
requirements, as described below.   We cannot assure you,
however, that we will ever be able to meet those requirements.

To qualify as a RIC, we must meet the issuer diversification
standards under the Internal Revenue Code that require that, at
the close of each quarter of our taxable year,

*	not more than 25% of the market value of our total assets
      is invested in the securities of a single issuer, and
*	at least 50% of the market value of our total assets is
      represented by cash, cash items, government securities,
      securities of other RICs, and other securities.

Each investment in these other securities is limited so that not
more than 5% of the market value of our total assets is invested
in the securities of a single issuer and we do not own more than
10% of the outstanding voting securities of a single issuer.
For purposes of the diversification requirements under the
Internal Revenue Code, the percentage of our total assets
invested in securities of a portfolio company will be deemed to
refer, in the case of financings in which we commit to provide
financing prior to funding the commitment, to the amount of our
total assets represented by the value of the securities issued
by the eligible portfolio company to us at the time each portion
of the commitment is funded.

Investment Amounts

The amount of funds committed to a portfolio company and the
ownership percentage received will vary depending on the
maturity of the portfolio company, the quality and completeness
of the portfolio company's management team, the perceived
business opportunity, the capital required compared to existing
capital, and the potential return.   Although investment amounts
will vary considerably, we expect that the average investment,
including follow-on investments, will be between $25,000 and
$500,000.

Competition

Our primary competitors to provide financing to target companies
will include private equity and venture capital funds, other
equity and non-equity based investment funds and investment
banks and other sources of financing, including traditional
financial services companies such as commercial banks and
specialty finance companies.  Many of these entities have
substantially greater financial and managerial resources than we
will have.   We believe that our competitive advantage with
regard to quality target companies relates to our ability to
negotiate flexible terms and to complete our review process on a
timely basis.   We cannot assure you that we will be successful
in implementing our strategies.

THE COMPANY AND ITS STRUCTURE

The Board of Directors and its Committees

The Board of directors is empowered to manage and oversee the
operations of a BDC.  .  As such, these decisions will be made
according to guidelines adopted for that purpose.  All directors
will be reimbursed by the Company for any expenses incurred in
attending directors' meetings provided that the Company has the
resources to pay these fees.  The Company intends to applying
for officers and directors liability insurance at such time when
it has the resources to do so.  The Company will maintain
whatever insurance and surety bonds are necessary when holding
physical certificates and other assets in possession.

Audit Committee

An Audit Committee charter has been accepted and under the
independent directorship control of a majority of independent
directors.  The audit committee will review the results and
scope of the audit and other services provided by the
independent auditors and review and evaluate the system of
internal controls.   The audit committee will assist in
determining the carrying values of portfolio investments.

Investment Committee

An Investment Committee charter and policy has been approved by,
and is under the directorship control of, a majority of
independent directors.  The function of the charter and the
committee will be to review and approve all investments in
excess of $25,000 and assist in determining the carrying values
of portfolio investments.

Compensation Committee

A Compensation Committee charter and policy has been approved
by, and is under the directorship of, a majority of independent
directors.  The purpose of the compensation committee will be to
manage the stock option plan and review and recommend
compensation arrangements for the officers.

Nominating Committee

A Nominating Committee charter has been accepted and under the
independent directorship control of a majority of independent
directors. The primary role of the Nominating Committee is to
actively seek individuals qualified to become members of the
board of directors, while ensuring that proper evaluations and
performances are upheld within the boards.

Verification of Independent Directors

A resolution has been adopted and a policy for determination of
Directors independence has been established.  Our independent
directors have proclaimed and established themselves as
independent via the following proclamation as established by the
Independence Charter, including:

*	within the last five (5) years, has not received more than
      $50,000 per year in direct compensation from the
      Corporation or any of its affiliates other than director
      and committee fees and pension or other forms of deferred
      compensation for prior service (provided such compensation
      is not contingent in any way on continued service);
*	within the last five (5) years, has not been affiliated
      with or employed by any independent audit firm presently
      acting as auditor of the Corporation or an affiliate of the
      Corporation or having acted as such an auditor during the

      previous 5 years;
*	within the past five (5) years, has had no personal service
      relationships and has not been affiliated with an
      organization that has had a personal service relationship
      with the Corporation, or with a member of the Corporation's
      senior management;
*	within the past (5) years, has not accepted any fee or
      compensation from the Corporation other than director's
      fees and compensation;
*	within the last five (5) years, has not had any material
      business relationship (such as commercial, industrial,
      consulting, legal, or accounting) with the Corporation for
      which the Corporation has been required to make disclosure
      under Regulation S-K of the Securities and Exchange
      Commission; and;
*	within the past five (5) years, has not been part of an
      interlocking directorate in which an executive officer of
      the Corporation serves on the compensation committee or a
      committee of a similar nature of another company that
      concurrently employs the director.

Stock Option Plan

There presently is no stock option plan.

Executive Compensation

No officer, director or employee has received any cash
compensation to date, and no director, officer or employee has a
contract or commitment to receive annual compensation in excess
of $100,000.   Each officer will be paid a negotiated percentage
of profits for the events that they arrange.   They will receive
no other compensation from us until we are operating profitably.

Conflicts of Interest

None of our key personnel is required to commit full time to our
affairs and, accordingly, these individuals may have conflicts
of interest in allocating management time among their various
business activities.   In the course of their other business
activities, certain key personnel may become aware of investment
and business opportunities which may be appropriate for
presentation to us, as well as the other entities with which
they are affiliated.    As such, they may have conflicts of
interest in determining to which entity a particular business
opportunity should be presented.

Each officer and director is, so long as he is officer or
director subject to the restriction that all opportunities
contemplated by our plan of operation that come to his
attention, either in the performance of his duties or in any
other manner, will be considered opportunities of, and be made
available to us and the companies that he is affiliated with on
an equal basis.   A breach of this requirement will be a breach
of the fiduciary duties of the officer or director.   If we, or
the companies to which the officer or director is affiliated,
desire to take advantage of an opportunity, then the applicable
officer or director would abstain from negotiating and voting
upon the opportunity.    However, to the extent permitted under
the 1940 Act, the officer or director may take advantage of
opportunities if we should decline to do so.   Except as set
forth above, we have not adopted any other conflict of interest
policy in connection with these types of transactions.

Code of Ethics

We have adopted a code of ethics pursuant to Rule 17j-1 under
the 1940 Act that establishes procedures for personal
investments and restricts certain personal securities
transactions.   Personnel subject to each code may invest in
securities for their personal investment accounts, including
securities that may be purchased or held by us, so long as such
investments are made in accordance with the code's requirements.

Employees

As of December 27, 2004, we had 0 employees.  Various aspects of
due diligence of prospective portfolio companies and monitoring
the activities of portfolio companies will be subcontracted to
consultants. The Company may require additional employees in the
areas of administration, sales and marketing, etc. in the future
and as additional portfolio companies are added. There is
intense competition for capable, experienced personnel and there
is no assurance the Company will be able to obtain new qualified
employees when required.  The Company believes its relations with
its prospective consultants and employees are good.


PORTFOLIO COMPANIES

Current Portfolio Investments

There are no current portfolio companies at this time.

FINANCIAL AND OTHER INFORMATION

Other Regulatory Matters

We are a business development company under the 1940 Act.   The
1940 Act contains prohibitions and restrictions relating to
transactions between business development companies and their
affiliates, including any investment advisers or sub-advisers,
principal underwriters and affiliates of those affiliates or
underwriters and requires that a majority of the directors be
persons other than interested persons, as that term is defined
in the 1940 Act.   In addition, the 1940 Act provides that we
may not change the nature of our business so as to cease to be,
or to withdraw our election as, a business development company
unless approved by a majority of our outstanding voting
securities.

We are permitted, under specified conditions, to issue multiple
classes of indebtedness and one class of stock senior to our
common stock if our asset coverage, as defined in the 1940 Act,
is at least equal to 200% immediately after each such issuance.
In addition, while any senior securities remain outstanding, we
must make provisions to prohibit any distribution to our
stockholders or the repurchase of such securities or shares
unless we meet the applicable asset coverage ratios at the time
of the distribution or repurchase.   We may also borrow amounts
up to 5% of the value of our total assets for temporary or
emergency purposes.   Regulations governing our operation as a
BDC will affect our ability to, and the way in which we raise
additional capital, which may expose us to risks, including the
typical risks associated with leverage.

No new pronouncement issued by the Financial Accounting
Standards Board, the American Institute of Certified Public
Accountants or the Securities and Exchange Commission is
expected to have a material impact on The Company's financial
position or reported results of operations.

Determination of Net Asset Value

The net asset value per share of our outstanding shares of
common stock will be determined quarterly, as soon as
practicable after, and as of the end of, each calendar quarter,
by dividing the value of total assets minus total liabilities by
the number of shares outstanding at the date as of which such
determination is made.

In calculating the value of our total assets, we will value
securities that are publicly traded at the closing price on the
valuation date for exchange traded and NASDAQ listed securities
or the average of the bid and asked prices for other securities.
Debt and equity securities that are not publicly traded will be
valued at fair value as determined in good faith by a valuation
committee of our board of directors based on the recommendation
by our investment adviser and under valuation guidelines adopted
by our board of directors, and then approved by our entire board
of directors. Initially, the fair value of these securities will
be their original cost.  Debt securities valued at cost would be
revalued for significant events affecting the issuer's
performance and equity securities valued at cost would be
revalued if significant developments or other factors affecting
the investment provide a basis for valuing the security at a
price other than cost, such as

*	results of subsequent financing,
*	the availability of market quotations,
*	the portfolio company's operations and
*	changes in market conditions.

For warrants, our cost usually will be a nominal amount, such as
$.01 per share.   Debt securities with remaining maturities of
60 days or less at the time of purchase will be valued at
amortized cost.  Debt securities which are publicly traded will
be valued by using market quotations obtained from pricing
services or dealers.   Our valuation guidelines will be subject
to periodic review by our board of directors and may be revised
in light of our experience, regulatory developments or
otherwise.

Determination of fair values involves subjective judgment and
estimates not susceptible to substantiation by auditing
procedures.  Accordingly, under current auditing standards, the
notes to our financial statements will refer to the uncertainty
with respect to the possible effect of such valuations, and any
change in such valuations, on our financial statements.


ITEM 9.01. FINANCIAL STATEMENTS AND EXHIBITS.

(a) Financial Statements of Business Acquired

None.

(b) Pro Forma Financial Statements

None

(c) Exhibits

None

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of
1934, as amended, this report has been signed below by the
following person on behalf of the Registrant and in the capacity
thereunto duly authorized, in Tucson, Arizona, on the 27nd day of
December 2004.

Bronco Energy Fund, Inc.

By:

/s/ Dan Baker

Dan Baker, Chief Executive Officer

EXHIBIT INDEX

Exhibits

None.
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SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C.  20549
              ____________________________________________________

                                    FORM 8-K
                                 CURRENT REPORT
          Pursuant to Section 13 or 15(d) of the Securities Exchange Act
                                    of 1934

                               December 27, 2004
                Date of Report (Date of earliest event reported)
             ____________________________________________________

                            BRONCO ENERGY FUND, INC.
            (Exact name of registrant as specified in its charter)

                                    Nevada
         (State or other jurisdiction of incorporation or organization)

                                  814-00690
                             (Commission File No.)

                                 86-0972709
                     (IRS Employer Identification Number)

          2920 N. Swan Suite 206, Tucson AZ 		  85712
       (Address of principal executive offices)       (Zip Code)

                               (866) 305-1755
                  (Telephone number, including area code

Check the appropriate box below if the Form 8-K filing is intended to
simultaneously satisfy the filing obligation of the registrant under any of
the following provisions (see General Instruction A.2. below):

{ } Written communications pursuant to Rule 425 under the Securities Act
    (17 CFR 230.425)

[ ] Soliciting material pursuant to Rule 14a-12 under the Securities
	Exchange Act (17 CFR 240.14a-12)

[ ] Pre-commencement communications pursuant to Rule 14d-2(b) under the
       Exchange Act (17 CFR 240.14d-2(b))

[ ] Pre-commencement communications pursuant to Rule 13e-4(c) under the
         Exchange Act (17 CFR 240.13e-4(c))

       _____________________________________________________________

Section 8  OTHER EVENTS

Item 8.01. Other Events.   Bronco Energy Fund, Inc. (the
Company), is a publicly traded Nevada corporation formed in June
1997 with its principal offices and operations center in Tucson,
Arizona. The Company has recently filed a notification under Form
N54a with the U.S. Securities and Exchange Commission, (the SEC)
indicating its election to be regulated as a business development
company under the Investment Company Act of 1940 (the ?1940 Act?).
In connection with this election, the Company has adopted
corporate resolutions and intends to operate as a closed-end
management investment company as such a business development
company (a BDC).  We disclose the following information which is
a material departure from our prior business plan.

INVESTMENT STRATEGY

We have conducted limited operations to date. Under this recent
election, we have been organized to provide investors with the
opportunity to participate, with a modest amount in venture
capital, in investments that are generally not available to the
public and that typically require substantially larger financial
commitments. In addition, we will provide professional
management and administration that might otherwise be
unavailable to investors if they were to engage directly in
venture capital investing.  We have decided to be regulated as a
business development company under the 1940 Act, and will
operate as a non-diversified company as that term is defined in
Section 5(b)(2) of the 1940 Act.  We will, at all times, conduct
our business so as to retain our status as a BDC.   We may not
change the nature of our business so as to cease to be, or
withdraw our election as, a BDC without the approval of the
holders of a majority of our outstanding voting stock as defined
under the 1940 Act.

As a business development company, we are required to invest at
least 70% of our total assets in qualifying assets, which,
generally, are securities of private companies or securities of
public companies whose securities are not eligible for purchase
on margin (which includes many companies with thinly traded
securities that are quoted in the pink sheets or the NASD
Electronic Quotation Service.)   We must also offer to provide
significant managerial assistance to these portfolio companies.
Qualifying assets may also include:

*	cash,
*	cash equivalents,
*	U.S. Government securities, or
*	high-quality debt investments maturing in one year or less
from the date of investment.

We may invest a portion of the remaining 30% of our total assets
in debt and/or equity securities of companies that may be larger
or more stabilized than target portfolio companies.

Nature of a BDC

The 1940 Act defines a BDC as a closed-end management investment
company that provides small businesses that qualify as an
eligible portfolio company with investment capital and also
significant managerial assistance.  A BDC is required under the
1940 Act to invest at least 70% of its total assets in
qualifying assets consisting of eligible portfolio companies as
defined in the 1940 Act and certain other assets including cash
and cash equivalents.

An eligible portfolio company generally is a United States
company that is not an investment company and that:

*	does not have a class of securities registered on an
exchange or included in the Federal Reserve Board's over-
the-counter margin list;
*	is actively controlled by a BDC and has an affiliate of a
BDC on its board of directors; or
*	meets such other criteria as may be established by the SEC.

Control under the 1940 Act is presumed to exist where a BDC owns
more than 25% of the outstanding voting securities of the
eligible portfolio company.  We may or may not control our
portfolio companies.
An example of an eligible portfolio company is a new start up
company or a privately owned company that has not yet gone
public by selling its shares in the open market and has not
applied for having its shares listed on a nationally recognized
exchange such as the NYSE the American Stock Exchange, National
Association of Securities Dealers' Automated Quotation System,
or the National Market System.  An eligible portfolio company
can also be one which is subject to filing, has filed, or has
recently emerged from reorganization protection under Chapter 11
of the Bankruptcy Act.

A BDC may invest the remaining 30% of its total assets in non-
qualifying assets, including companies that are not eligible
portfolio companies.  The foregoing percentages will be
determined, in the case of financings in which a BDC commits to
provide financing prior to funding the commitment, by the amount
of the BDC's total assets represented by the value of the
maximum amount of securities to be issued by the borrower or
lessee to the BDC pursuant to such commitment.   As a BDC, we
must invest at least 70% of our total assets in qualifying
assets but may invest more in such qualifying assets.

Primary Strategy

We will have significant relative flexibility in selecting and
structuring our investments.  We will not be subject to many of
the regulatory limitations that govern traditional lending
institutions such as banks.   We will seek to structure our
investments so as to take into account the uncertain and
potentially variable financial performance of our portfolio
companies.   This should enable our portfolio companies to
retain access to committed capital at different stages in their
development and eliminate some of the uncertainty surrounding
their capital allocation decisions.   We will calculate rates of
return on invested capital based on a combination of up-front
commitment fees, current and deferred interest rates and
residual values, which may take the form of common stock,
warrants, equity appreciation rights or future contract
payments.   We believe that this flexible approach to
structuring investments will facilitate positive, long-term
relationships with our portfolio companies and enable us to
become a preferred source of capital to them.   We also believe
our approach should enable debt financing to develop into a
viable alternative capital source for funding the growth of
target companies that wish to avoid the dilutive effects of
equity financings for existing equity holders.

Longer Investment Horizon - We will not be subject to periodic
capital return requirements.   These requirements, which are
standard for most private equity and venture capital funds,
typically require that these funds return to investors the
initial capital investment after a pre-agreed time, together
with any capital gains on such capital investment.   These
provisions often force such funds to seek the return of their
investments in portfolio companies through mergers, public
equity offerings or other liquidity events more quickly than
they otherwise might, which can result in a lower overall return
to investors and adversely affect the ultimate viability of the
affected portfolio companies.  Because we may invest in the same
portfolio companies as these funds, we are subject to these
risks if these funds demand a return on their investments in the
portfolio companies.  We believe that our flexibility to take a
longer-term view should help us to maximize returns on our
invested capital while still meeting the needs of our portfolio
companies.

Established Deal Sourcing Network - We believe that, through our
management and directors, we have solid contacts and sources
from which to generate investment opportunities. These contacts
and sources include:

*	public and private companies,
*	investment bankers,
*	attorneys,
*	accountants,
*	consultants, and
*	commercial bankers.

However, we cannot assure you that such relationships will lead
to the origination of debt or other investments.

Investment Criteria

As a matter of policy, we will not purchase or sell real estate
or interests in real estate or real estate investment trusts
except that we may:

*	purchase and sell real estate or interests in real estate
in connection with the orderly liquidation of investments,
or in connection with foreclosure on collateral;
*	own the securities of companies that are in the business of
buying, selling or developing real estate; or
*	finance the purchase of real estate by our portfolio
companies.

We will limit our investments in more traditional securities
(stock and debt instruments) and will not, as a matter of
policy:

*	sell securities short except with regard to managing the
risks associated with publicly-traded securities issued by
our portfolio companies;
*	Purchase securities on margin (except to the extent that we
may purchase securities with borrowed money); or
*	engage in the purchase or sale of commodities or commodity
contracts, including futures contracts except where
necessary in working out distressed loan; or
*	investment situations or in hedging the risks associated
with interest rate fluctuations, and, in such cases, only
after all necessary registrations or exemptions from
registration with the Commodity Futures Trading Commission
have been obtained.

Prospective Portfolio Company Characteristics - We have
identified several criteria that we believe will prove important
in seeking our investment objective with respect to target
companies.   These criteria will provide general guidelines for
our investment decisions; however, we caution readers that not
all of these criteria will be met by each prospective portfolio
company in which we choose to invest.

Experienced Management - We will generally require that our
portfolio companies have an experienced president or management
team.   We will also require the portfolio companies to have in
place proper incentives to induce management to succeed and to
act in concert with our interests as investors, including having
significant equity interests.  We intend to provide assistance
in this area either supervising management or providing
management for our portfolio companies.

Products or Services - We will seek companies that are involved
in products or services that do not require significant
additional capital or research expenditures.  In general, we
will seek target companies that make innovative use of proven
technologies or methods.

Proprietary Advantage - We expect to favor companies that can
demonstrate some kind of proprietary sustainable advantage with
respect to their competition.  Proprietary advantages include,
but are not limited to:

*	patents or trade secrets with respect to owning or
manufacturing its products, and
*	a demonstrable and sustainable marketing advantage over its
competition

Marketing strategies impose unusual burdens on management to be
continuously ahead of its competition, either through some kind
of technological advantage or by being continuously more
creative than its competition.

Profitable or Nearly Profitable Operations Based on Cash Flow
from Operations - We will focus on target companies that are
profitable or nearly profitable on an operating cash flow basis.
Typically, we would not expect to invest in start-up companies
unless there is a clear exit strategy in place.

Potential for Future Growth - We will generally require that a
prospective target company, in addition to generating sufficient
cash flow to cover its operating costs and service its debt,
demonstrate an ability to increase its revenues and operating
cash flow over time.   The anticipated growth rate of a
prospective target company will be a key factor in determining
the value that we ascribe to any warrants or other equity
securities that we may acquire in connection with an investment
in debt securities.

Exit Strategy. Prior to making an investment in a portfolio
company, we will analyze the potential for that company to
increase the liquidity of its common equity through a future
event that would enable us to realize appreciation, if any, in
the value of our equity interest.   Liquidity events may
include:

*	an initial public offering,
*	a private sale of our equity interest to a third party,
*	a merger or an acquisition of the portfolio company, or
*	a purchase of our equity position by the portfolio company
      or one of its stockholders.

We may acquire warrants to purchase equity securities and/or
convertible preferred stock of the eligible portfolio companies
in connection with providing financing.   The terms of the
warrants, including the expiration date, exercise price and
terms of the equity security for which the warrant may be
exercised, will be negotiated individually with each eligible
portfolio company, and will likely be affected by the price and
terms of securities issued by the eligible portfolio company to
other venture capitalists and other holders.   We anticipate
that most warrants will be for a term of five to ten years, and
will have an exercise price based upon the price at which the
eligible portfolio company most recently issued equity
securities or, if a new equity offering is imminent, equity
securities.    The equity securities for which the warrant will
be exercised generally will be common stock of which there may
be one or more classes or convertible preferred stock.
Substantially all the warrants and underlying equity securities
will be restricted securities under the 1933 Act at the time of
the issuance.   We will generally negotiate for registration
rights with the issuer that may provide:

*	?piggyback" registration rights, which will permit us under
certain circumstances, to include some or all of the
securities owned by us in a registration statement filed by
the eligible portfolio company, or
*	in circumstances, "demand" registration rights permitting
us under certain circumstances, to require the eligible
portfolio company to register the securities under the 1933
Act, in some cases at our expense.   We will generally
negotiate net issuance provisions in the warrants, which
will allow us to receive upon exercise of the warrant
without payment of any cash a net amount of shares
determined by the increase in the value of the issuer's
stock above the exercise price stated in the warrant.

Liquidation Value of Assets - Although we do not intend to
operate as an asset-based lender, the prospective liquidation
value of the assets, if any, collateralizing any debt securities
that we hold will be an important factor in our credit analysis.
We will emphasize both tangible assets, such as:

*	accounts receivable,
*	inventory, and
*	equipment,

and intangible assets, such as:

*	intellectual property,
*	customer lists,
*	networks, and
*	databases.

Investment Process

Due Diligence - If a target company generally meets the
characteristics described above, we will perform initial due
diligence, including:
*	company and technology assessments,
*	existing management team,
*	market analysis,
*	competitive analysis,
*	evaluation of management, risk analysis and transaction
      size,
*	pricing, and
*	structure analysis.

Much of this work will be done by management and professionals
who are well known by management.  The criteria delineated above
provide general parameters for our investment decisions.  We
intend to pursue an investment strategy by further imposing such
criteria and reviews that best insures the value of our
investments.  As unique circumstances may arise or be uncovered,
not all of such criteria will be followed in each instance but
the process provides a guideline by which investments can be
prudently made and managed. Upon successful completion of the
preliminary evaluation, we will decide whether to deliver a non-
binding letter of intent and move forward towards the completion
of a transaction.

In our review of the management team, we look at the following:

*	Interviews with management and significant shareholders,
      including any financial or strategic sponsor;
*	Review of financing history;
*	Review of management's track record with respect to:
o	product development and marketing,
o	mergers and acquisitions,
o	alliances,
o	collaborations,
o	research and development outsourcing and other
      strategic activities;
*	Assessment of competition; and
*	Review of exit strategies.

In our review of the financial conditions, we look at the
following:

*	Evaluation of future financing needs and plans;
*	Detailed analysis of financial performance;
*	Development of pro forma financial projections; and
*	Review of assets and liabilities, including contingent
      Liabilities, if any, and legal and regulatory risks.

In our review of the products and services of the portfolio
company, we look at the following:

*	Evaluation of intellectual property position;
*	Review of existing customer or similar agreements and
      arrangements;
*	Analysis of core technology;
*	Assessment of collaborations;
*	Review of sales and marketing procedures; and
*	Assessment of market and growth potential.

Upon completion of these analyses, we will conduct on-site
visits with the target company's management team.   Also, in
cases in which a target company is at a mature stage of
development and if other matters that warrant such an
evaluation, we will obtain an independent appraisal of the
target company.

Ongoing Relationships with Portfolio Companies

Monitoring - We will continuously monitor our portfolio
companies in order to determine whether they are meeting our
financing criteria and their respective business plans.   We may
decline to make additional investments in portfolio companies
that do not continue to meet our financing criteria.   However,
we may choose to make additional investments in portfolio
companies that do not do so, but we believe that we will
nevertheless perform well in the future.

We will monitor the financial trends of each portfolio company
to assess the appropriate course of action for each company and
to evaluate overall portfolio quality.  Our management team and
consulting professionals, who are well known by our management
team, will closely monitor the status and performance of each
individual company on at least a quarterly and, in some cases, a
monthly basis.

We will use several methods of evaluating and monitoring the
performance and fair value of our debt and equity positions,
including but not limited to the following:

*	Assessment of business development success, including
      product development, financings, profitability and the
      portfolio company's overall adherence to its business plan;
*	Periodic and regular contact with portfolio company
      management to discuss financial position, requirements and
      accomplishments;
*	Periodic and regular formal update interviews with
      portfolio company management and, if appropriate, the
      financial or strategic sponsor;
*	Attendance at and participation in board meetings;
*	Review of monthly and quarterly financial statements and
      financial projections for portfolio companies.

Managerial Assistance - As a business development company, we
will offer, and in many cases may provide, significant
managerial assistance to our portfolio companies.   This
assistance will typically involve:

*	monitoring the operations of our portfolio companies,
*	participating in their board and management meetings,
*	consulting with and advising their officers, and
*	providing other organizational and financial guidance.

Diversification

As a BDC, we must invest at least 70% of our total assets in
qualifying assets consisting of investments in eligible
portfolio companies and certain other assets including cash and
cash equivalents.   In order to receive favorable pass-through
tax treatment on its distributions to our shareholders, we
intend to diversify our pool of investments in such a manner so
as to qualify as a diversified closed end management investment
company.   However, because of the limited size of the funding
which is likely to be available to us, we will likely be
classified as a non-diversified closed end investment company
under the 1940 Act.  Until we qualify as a registered investment
company, we will not be subject to the diversification
requirements applicable to RICs under the Internal Revenue Code.
Therefore, we will not receive favorable pass through tax
treatment on distributions to our shareholders.   In the future,
we will seek to increase the diversification of our portfolio so
as to make it possible to meet the RIC diversification
requirements, as described below.   We cannot assure you,
however, that we will ever be able to meet those requirements.

To qualify as a RIC, we must meet the issuer diversification
standards under the Internal Revenue Code that require that, at
the close of each quarter of our taxable year,

*	not more than 25% of the market value of our total assets
      is invested in the securities of a single issuer, and
*	at least 50% of the market value of our total assets is
      represented by cash, cash items, government securities,
      securities of other RICs, and other securities.

Each investment in these other securities is limited so that not
more than 5% of the market value of our total assets is invested
in the securities of a single issuer and we do not own more than
10% of the outstanding voting securities of a single issuer.
For purposes of the diversification requirements under the
Internal Revenue Code, the percentage of our total assets
invested in securities of a portfolio company will be deemed to
refer, in the case of financings in which we commit to provide
financing prior to funding the commitment, to the amount of our
total assets represented by the value of the securities issued
by the eligible portfolio company to us at the time each portion
of the commitment is funded.

Investment Amounts

The amount of funds committed to a portfolio company and the
ownership percentage received will vary depending on the
maturity of the portfolio company, the quality and completeness
of the portfolio company's management team, the perceived
business opportunity, the capital required compared to existing
capital, and the potential return.   Although investment amounts
will vary considerably, we expect that the average investment,
including follow-on investments, will be between $25,000 and
$500,000.

Competition

Our primary competitors to provide financing to target companies
will include private equity and venture capital funds, other
equity and non-equity based investment funds and investment
banks and other sources of financing, including traditional
financial services companies such as commercial banks and
specialty finance companies.  Many of these entities have
substantially greater financial and managerial resources than we
will have.   We believe that our competitive advantage with
regard to quality target companies relates to our ability to
negotiate flexible terms and to complete our review process on a
timely basis.   We cannot assure you that we will be successful
in implementing our strategies.

THE COMPANY AND ITS STRUCTURE

The Board of Directors and its Committees

The Board of directors is empowered to manage and oversee the
operations of a BDC.  .  As such, these decisions will be made
according to guidelines adopted for that purpose.  All directors
will be reimbursed by the Company for any expenses incurred in
attending directors' meetings provided that the Company has the
resources to pay these fees.  The Company intends to applying
for officers and directors liability insurance at such time when
it has the resources to do so.  The Company will maintain
whatever insurance and surety bonds are necessary when holding
physical certificates and other assets in possession.

Audit Committee

An Audit Committee charter has been accepted and under the
independent directorship control of a majority of independent
directors.  The audit committee will review the results and
scope of the audit and other services provided by the
independent auditors and review and evaluate the system of
internal controls.   The audit committee will assist in
determining the carrying values of portfolio investments.

Investment Committee

An Investment Committee charter and policy has been approved by,
and is under the directorship control of, a majority of
independent directors.  The function of the charter and the
committee will be to review and approve all investments in
excess of $25,000 and assist in determining the carrying values
of portfolio investments.

Compensation Committee

A Compensation Committee charter and policy has been approved
by, and is under the directorship of, a majority of independent
directors.  The purpose of the compensation committee will be to
manage the stock option plan and review and recommend
compensation arrangements for the officers.

Nominating Committee

A Nominating Committee charter has been accepted and under the
independent directorship control of a majority of independent
directors. The primary role of the Nominating Committee is to
actively seek individuals qualified to become members of the
board of directors, while ensuring that proper evaluations and
performances are upheld within the boards.

Verification of Independent Directors

A resolution has been adopted and a policy for determination of
Directors independence has been established.  Our independent
directors have proclaimed and established themselves as
independent via the following proclamation as established by the
Independence Charter, including:

*	within the last five (5) years, has not received more than
      $50,000 per year in direct compensation from the
      Corporation or any of its affiliates other than director
      and committee fees and pension or other forms of deferred
      compensation for prior service (provided such compensation
      is not contingent in any way on continued service);
*	within the last five (5) years, has not been affiliated
      with or employed by any independent audit firm presently
      acting as auditor of the Corporation or an affiliate of the
      Corporation or having acted as such an auditor during the

      previous 5 years;
*	within the past five (5) years, has had no personal service
      relationships and has not been affiliated with an
      organization that has had a personal service relationship
      with the Corporation, or with a member of the Corporation's
      senior management;
*	within the past (5) years, has not accepted any fee or
      compensation from the Corporation other than director's
      fees and compensation;
*	within the last five (5) years, has not had any material
      business relationship (such as commercial, industrial,
      consulting, legal, or accounting) with the Corporation for
      which the Corporation has been required to make disclosure
      under Regulation S-K of the Securities and Exchange
      Commission; and;
*	within the past five (5) years, has not been part of an
      interlocking directorate in which an executive officer of
      the Corporation serves on the compensation committee or a
      committee of a similar nature of another company that
      concurrently employs the director.

Stock Option Plan

There presently is no stock option plan.

Executive Compensation

No officer, director or employee has received any cash
compensation to date, and no director, officer or employee has a
contract or commitment to receive annual compensation in excess
of $100,000.   Each officer will be paid a negotiated percentage
of profits for the events that they arrange.   They will receive
no other compensation from us until we are operating profitably.

Conflicts of Interest

None of our key personnel is required to commit full time to our
affairs and, accordingly, these individuals may have conflicts
of interest in allocating management time among their various
business activities.   In the course of their other business
activities, certain key personnel may become aware of investment
and business opportunities which may be appropriate for
presentation to us, as well as the other entities with which
they are affiliated.    As such, they may have conflicts of
interest in determining to which entity a particular business
opportunity should be presented.

Each officer and director is, so long as he is officer or
director subject to the restriction that all opportunities
contemplated by our plan of operation that come to his
attention, either in the performance of his duties or in any
other manner, will be considered opportunities of, and be made
available to us and the companies that he is affiliated with on
an equal basis.   A breach of this requirement will be a breach
of the fiduciary duties of the officer or director.   If we, or
the companies to which the officer or director is affiliated,
desire to take advantage of an opportunity, then the applicable
officer or director would abstain from negotiating and voting
upon the opportunity.    However, to the extent permitted under
the 1940 Act, the officer or director may take advantage of
opportunities if we should decline to do so.   Except as set
forth above, we have not adopted any other conflict of interest
policy in connection with these types of transactions.

Code of Ethics

We have adopted a code of ethics pursuant to Rule 17j-1 under
the 1940 Act that establishes procedures for personal
investments and restricts certain personal securities
transactions.   Personnel subject to each code may invest in
securities for their personal investment accounts, including
securities that may be purchased or held by us, so long as such
investments are made in accordance with the code's requirements.

Employees

As of December 27, 2004, we had 0 employees.  Various aspects of
due diligence of prospective portfolio companies and monitoring
the activities of portfolio companies will be subcontracted to
consultants. The Company may require additional employees in the
areas of administration, sales and marketing, etc. in the future
and as additional portfolio companies are added. There is
intense competition for capable, experienced personnel and there
is no assurance the Company will be able to obtain new qualified
employees when required.  The Company believes its relations with
its prospective consultants and employees are good.

PORTFOLIO COMPANIES

Current Portfolio Investments

There are no current portfolio companies at this time.

FINANCIAL AND OTHER INFORMATION

Other Regulatory Matters

We are a business development company under the 1940 Act.   The
1940 Act contains prohibitions and restrictions relating to
transactions between business development companies and their
affiliates, including any investment advisers or sub-advisers,
principal underwriters and affiliates of those affiliates or
underwriters and requires that a majority of the directors be
persons other than interested persons, as that term is defined
in the 1940 Act.   In addition, the 1940 Act provides that we
may not change the nature of our business so as to cease to be,
or to withdraw our election as, a business development company
unless approved by a majority of our outstanding voting
securities.

We are permitted, under specified conditions, to issue multiple
classes of indebtedness and one class of stock senior to our
common stock if our asset coverage, as defined in the 1940 Act,
is at least equal to 200% immediately after each such issuance.
In addition, while any senior securities remain outstanding, we
must make provisions to prohibit any distribution to our
stockholders or the repurchase of such securities or shares
unless we meet the applicable asset coverage ratios at the time
of the distribution or repurchase.   We may also borrow amounts
up to 5% of the value of our total assets for temporary or
emergency purposes.   Regulations governing our operation as a
BDC will affect our ability to, and the way in which we raise
additional capital, which may expose us to risks, including the
typical risks associated with leverage.

No new pronouncement issued by the Financial Accounting
Standards Board, the American Institute of Certified Public
Accountants or the Securities and Exchange Commission is
expected to have a material impact on The Company's financial
position or reported results of operations.

Determination of Net Asset Value

The net asset value per share of our outstanding shares of
common stock will be determined quarterly, as soon as
practicable after, and as of the end of, each calendar quarter,
by dividing the value of total assets minus total liabilities by
the number of shares outstanding at the date as of which such
determination is made.

In calculating the value of our total assets, we will value
securities that are publicly traded at the closing price on the
valuation date for exchange traded and NASDAQ listed securities
or the average of the bid and asked prices for other securities.
Debt and equity securities that are not publicly traded will be
valued at fair value as determined in good faith by a valuation
committee of our board of directors based on the recommendation
by our investment adviser and under valuation guidelines adopted
by our board of directors, and then approved by our entire board
of directors. Initially, the fair value of these securities will
be their original cost.  Debt securities valued at cost would be
revalued for significant events affecting the issuer's
performance and equity securities valued at cost would be
revalued if significant developments or other factors affecting
the investment provide a basis for valuing the security at a
price other than cost, such as

*	results of subsequent financing,
*	the availability of market quotations,
*	the portfolio company's operations and
*	changes in market conditions.

For warrants, our cost usually will be a nominal amount, such as
$.01 per share.   Debt securities with remaining maturities of
60 days or less at the time of purchase will be valued at
amortized cost.  Debt securities which are publicly traded will
be valued by using market quotations obtained from pricing
services or dealers.   Our valuation guidelines will be subject
to periodic review by our board of directors and may be revised
in light of our experience, regulatory developments or
otherwise.

Determination of fair values involves subjective judgment and
estimates not susceptible to substantiation by auditing
procedures.  Accordingly, under current auditing standards, the
notes to our financial statements will refer to the uncertainty
with respect to the possible effect of such valuations, and any
change in such valuations, on our financial statements.

ITEM 9.01. FINANCIAL STATEMENTS AND EXHIBITS.

(a) Financial Statements of Business Acquired

None.

(b) Pro Forma Financial Statements

None

(c) Exhibits

None

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of
1934, as amended, this report has been signed below by the
following person on behalf of the Registrant and in the capacity
thereunto duly authorized, in Tucson, Arizona, on the 27nd day of
December 2004.

Bronco Energy Fund, Inc.

By:

/s/ Dan Baker

Dan Baker, Chief Executive Officer

EXHIBIT INDEX

Exhibits

None.