Mail Stop 4720
                                                              October 9, 2018

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.
               Amendment No. 3 to Registration Statement on Form S-1
               Filed September 24, 2018
               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.

Prospectus cover page

1. Please clarify which of the OTC Markets your common stock is traded on.

Risk Factors
Effectiveness of Disclosure Controls and Procedures; Effectiveness of
Internal..., page 10

2. We note the new disclosure in response to comment 2 that the Company has a
limitation on
   staffing "requiring specialized outside accounting assistance to implement
additional
   procedures that are effective, and another review to the process, to ensure
that all material
   information required to be filed in the annual report on Form 10-K has been
made known to
   them." Please clarify whether this "specialized outside accounting
assistance" is something
   you've been receiving that needs additional effective procedures implemented
or whether it
   is part of a future solution or something else. Please revise to further
clarify what has been
 John Pollock
Financial Gravity Companies, Inc.
October 9, 2018
Page 2

   detected to be problematic or contributing to the ineffectiveness and what
is determined to be
   a response to such matters.

3. We also note the new disclosure that the Company has implemented processes
to improve
   DCP and ICFR and address any material weaknesses that require involvement of
   "leadership team" members in check disbursements. Please clarify who is part
of the
   leadership team or how this group is defined.

4. Disclosure in this risk factor also indicates that "though adequate
processes are in place and
   functioning, subsequent reviews are deemed necessary to identify
unauthorized transactions."
   Please clarify why your processes are adequate if subsequent reviews are
needed to identify
   unauthorized transactions.

Management's Discussion and Analysis of Financial Condition... page 24

5. You appear to have removed your discussion relating to completed fiscal
years covered by
   the annual financial statements included in your filing. Please amend your
registration
   statement to ensure that your MD&A covers all required periods.

Executive Compensation, page 32

6. We note the revised disclosure in response to comment 9. Please expand to
disclose the
   aggregate grant date fair value of the option awards. Refer to Item
402(n)(2)(vi).


        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 202-551-3765
with any
questions.

                                                           Sincerely,

                                                           /s/ Pamela Long

                                                           Pamela Long
                                                           Assistant Director
                                                           Office of Financial
Services
 John Pollock
Financial Gravity Companies, Inc.
October 9, 2018
Page 3


cc:    Chase Chandler