November 14,
2018

Clayton Patterson
President
United Capital Consultants, Inc.
3210 E. Coralbell Ave.
Mesa, AZ 85204

       Re: United Capital Consultants, Inc.
           Registration Statement on Form S-1
           Filed October 18, 2018
           File No. 333-227881

Dear Mr. Patterson:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1

Cover Page

1.     You state that the company would receive $10 million if all the shares
in this offering are
       sold. Given that this is a best efforts offering, please balance the
disclosure by stating that
       there can be no assurance that the company will be able to sell any of
the shares being
       offered.
Prospectus Summary
Business, page 6

2.     Please clearly disclose that you have not generated any revenues to date
and there can be
 Clayton Patterson
FirstName LastNameClayton Patterson
United Capital Consultants, Inc.
Comapany 14, 2018
November NameUnited Capital Consultants, Inc.
November 14, 2018 Page 2
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FirstName LastName
         no assurance that you will ever generate revenues. Please also revise
the statements
         throughout the filing regarding your limited revenues to state that
you have had no
         revenues to date.
Risks and Uncertainties facing the Company, page 7

3.       Please disclose that your officers, directors and principal
shareholders currently have
         voting control over the company and will continue to have voting
control even if all the
         shares in this offering are sold.
Risk Factors, page 9

4.       You disclose in the Form 10-Q for the quarterly period ended June 30,
2018 that your
         management concluded that your disclosure controls and procedures were
not effective.
          Please add a separate risk factor that your disclosure controls and
procedures were not
         effective as of June 30, 2018. Describe any material weakness you have
identified, your
         plans to remediate those weaknesses, and any associated material costs
that you have
         incurred or expect to incur.
Risks Associated with our Company's Business, page 10

5.       Please add a risk factor disclosing any potential conflicts of
interest that may arise from
         the business activities of Messrs. Patterson and Patterson. In this
regard, you state that
         Clayton Patterson is the Chief Executive Officer of United Utilities
Authority Co., Ltd.
         and Chief Financial Officer of Patterson Enterprises, Inc. and Harold
Patterson is the
         Chief Executive Officer of Patterson Enterprises, Inc. Please disclose
whether you have
         policies in place regarding the manner in which your management will
resolve the types
         of conflicts of interest that you describe in this paragraph and
disclose the number of
         hours per week your officers will devote to the business.
Description of Our Business, page 22

6.       Please describe your "large group of affiliate and associate
companies" that you reference
         on page 26. Further, expand your description of the agreements with
your current clients
         that you reference on page 27. Disclose the material terms of each
agreement including
         the duration of and obligations under those agreements. We note that
you have not yet
         generated any revenue from these clients.
Plan of Operation
Business Plan and Potential Revenue, page 31

7.       Please provide a more detailed discussion of each of your planned
activities for the next
         12 months. For example, discuss the milestones necessary to design and
develop your
         proposed business, hire the necessary personnel and conduct your
marketing campaign,
         among other steps. Please also disclose the resources required to
complete each step of
 Clayton Patterson
FirstName LastNameClayton Patterson
United Capital Consultants, Inc.
Comapany 14, 2018
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November 14, 2018 Page 3
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FirstName LastName
         your business development, as well as the challenges you anticipate in
implementing your
         business plan.
Security Ownership of Certain Beneficial Owners and Management, page 42

8.       We note that Messrs. Cassidy and McKillop each own 250,000 shares of
the company's
         common stock. Please include these individuals in the beneficial
ownership table. Refer
         to Item 403(a) of Regulation S-K.

Certain Relationships and Related Party Transactions
Transactions with Related Persons, page 43

9.       We note that you have entered into an agreement with United Utilities
Authority Co., Ltd.
         for whom Mr. Patterson is the Chief Executive Officer. Please provide
the disclosure
         required by Item 404 of Regulation S-K related to this agreement.
Unaudited Financial Statements for the period ended June 30, 2018, page F-1

10.      Please include a subsequent events footnote that addresses any
material transactions
         occurring after the date of the most recent balance sheet included in
the filing. Refer to
         ASC 855-10-50-2.
General

11.      You appear to be a shell company as defined in Rule 405 given that you
         have no operations and nominal assets. As such, you should disclose
that you are a shell
         company on your prospectus cover page and add a risk factor that
highlights the
         consequences of shell company status. Discuss the prohibition on the
use of Form S-8 by
         shell companies, enhanced reporting requirements imposed on shell
companies, and the
         conditions that must be satisfied before restricted and control
securities may be resold in
         reliance on Rule 144. Also, describe the potential impact on your
ability to attract
         additional capital through subsequent unregistered offerings.
12.      Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Clayton Patterson
United Capital Consultants, Inc.
November 14, 2018
Page 4

       You may contact Brittany Ebbertt, Senior Staff Accountant, at (202)
551-3572 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have
questions regarding
comments on the financial statements and related matters. Please contact Jeff
Kauten, Staff
Attorney, at (202) 551-3447 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                         Sincerely,

FirstName LastNameClayton Patterson                      Division of
Corporation Finance
                                                         Office of Information
Technologies
Comapany NameUnited Capital Consultants, Inc.
                                                         and Services
November 14, 2018 Page 4
cc:       Jarvis Lagman
FirstName LastName