Mail Stop 4720

                                                             October 13, 2017

John Pollock
Chairman of the Board, Chief Executive Officer
Financial Gravity Companies, Inc.
800 N. Watters Road
Suite 120
Allen, TX 75013

       Re:     Financial Gravity Companies, Inc.
               Registration Statement on Form S-1
               Filed September 18, 2017
               File No. 333-220505

Dear Mr. Pollock:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

General

1. Please tell us whether you believe you currently have the ability to deliver
a put notice to
   GHS Investments pursuant to the equity financing agreement. In this regard
we note that
   Sections 2.3(iii) and 5.8 of the Agreement together appear to have
contractually required you
   to file a Form 8-K in connection with entering into the Agreement but you do
not appear to
   have made this filing. This suggests that you may be in breach of the
agreement and this in
   turn suggests that GHS is not irrevocably bound to pay for and accept all
the shares. Please
   note that if GHS is not irrevocably bound to pay for and accept all the
shares, you should
   withdraw this registration statement and refile a new registration statement
after the breach is
   cured or otherwise register the resale after the exercise of each put.
Please refer to our
   Questions 139.12 to 139.22 of our Compliance and Disclosure Interpretations,
which are
   available on our website.
 John Pollock
Financial Gravity Companies, Inc.
October 13, 2017
Page 2


2. Please disclose the material terms of, and file as exhibits, the
registration rights agreement
   and the $30,000 promissory note given to GHS Investments as a commitment fee
and
   referenced in Section 2.7 of the equity financing agreement.


        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.

       Please contact Jessica Livingston at 202-551-3448 or me at 202-551- 3338
with any
questions.


                                                             Sincerely,

                                                             /s/ Dietrich A.
King

                                                             Dietrich A. King
                                                             Assistant Director
                                                             Office of
Financial Services


cc:    Chase Chandler