November 30, 2017

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street., N.E.

Washington, D.C. 20549

Attention:	Suzanne Hayes, Assistant Director
	Dorie Yale, Staff Attorney

Re:	McGraw Conglomerate Corporation Offering Statement on Form 1-A File No. 024-10657
	REQUEST FOR INPUT, INCLUDING WHETHER ACCELERATION OF EFFECTIVENESS POSSIBLE

Dear Ms. Hayes:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, McGraw Conglomerate Corporation (the “Registrant”) has filed on Form 1-A (File No. 024-10657), as amended (the “Offering Statement”), pursuant to Rule 461 pro-mulgated under the Securities Act of 1933 (as amended). As you know, this Form 1-A was filed some 11 months ago. And yesterday, as Registrant’s Attorney of Record for this filing, I advised you yesterday via email that the efforts to get FINRA-cleared had been painfully slow, more than a month.

After yesterday’s exchange, Peter DiChiara (counsel for Alexander Capital, the best efforts selling agent for Registrant) advised Registrant that the 2^nd FINRA reviewer for this offering will be back in the office Monday and we can expect that review (and presumably clearance as to the offering’s brokerage compensation) Monday, perhaps Tuesday. Because we wish to avoid any unnecessary Amendments, we will not be so filing at least until we get either clearance or comments from FINRA early next week.

In that context, especially since we do not feel that these modest edits are material in character and we were planning to file as part of the 424(b) Offering Circular (not a separate Amendment), Mr. DiChiara suggested that we formally file as Correspon-dence on EDGAR the 3 pages affected by the single SEC comment (as well as the lone outstanding SEC comment).

1333 Sprucewood Deerfield, IL 60015 Fax: 484-450-5130; Phone: 847.948.5431 Randy@securitiescounselors.net

Assuming we are cleared by FINRA early next week as expected (among other reasons because the 1^st reviewer has no further comments), we have these three questions:

(1)	Are you satisfied with these proposed edits to the Offering Circular?
(2)	Do you have any objection to our including such changes as part of the finalized 424(b) Offering Circular, an Amendment not required?
(3)	Upon learning that FINRA has “cleared” the offering, may we then file Reg-istrant’s Request for Acceleration Letter seeking a date of ‘33 Act effectiveness 24 or 48 hours later?

Please advise upon receipt and review of this communication, whether via email or a phone call.

FYI, these materials are being filed as Correspondence on EDGAR.

Very truly yours,

Randall S. Goulding

SECURITIES COUNSELORS, INC.

Enclosures:

1.	Draft edits responsive to sole SEC comment
2.	Copy of SEC Comment dated November 22, 2017

1333 Sprucewood Deerfield, IL 60015	Phone: 847.948.5431	page 2
randy@securitiescounselors.net	Fax 484-450-5130