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                           September 30, 2020

       Jesse Correll
       Chief Executive Officer
       UTG, Inc.
       205 North Depot Street
       Stanford, KY 40484

                                                        Re: UTG, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed March 20,
2020
                                                            Form 10-Q for
Quarterly Period Ended June 30, 2020
                                                            Filed August 11,
2020
                                                            File No. 000-16867

       Dear Mr. Correll:

              We have reviewed your September 3, 2020 response to our comment
letter 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       August 21, 2020 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Note 2. Investments

   1.                                                   We note your response
to prior comment 2, including your proposed disclosure in Exhibit
                                                        B for investment real
estate. Please address the following:

                                                              Tell us how you
considered the guidance in ASC 360-10-35-44 upon your change in
                                                            classification from
held-for-sale to held-for-investment;
                                                              Notwithstanding
your net real estate sales of $3,418,671 for the six months ended
                                                            June 30, 2020, it
appears that you reclassified a significant amount of raw land to
                                                            land with minerals
and royalty interests. If this is true, revise your proposed
 Jesse Correll
FirstName
UTG, Inc. LastNameJesse Correll
Comapany 30,
September  NameUTG,
               2020 Inc.
September
Page  2    30, 2020 Page 2
FirstName LastName
              disclosure in Exhibit B to clarify why you made such a
reclassification. If this is not
              true, tell us why these balances changed; and
                Tell us why the fair value of your investment in real estate
was $85,158,424 at both
              December 31, 2019 and June 30, 2020 when you sold $3,418,671 of
these
              investments during this six-month period.

         Provide us with your revised disclosures as appropriate.

Note 3. Fair Value Measurements

2.       We note your response to prior comment 4, including in your proposed
disclosure in
         Exhibit C that includes common stock categorized as Level 3 within the
fair value
         hierarchy for investments valued at net asset value. Please tell how
these investments
         comply with ASC 820-10-15-4 and 15-5, remove these investments from
your Level 3
         disclosures as required by ASC 820-10-35-54B, as appropriate, and
provide the
         disclosures required by ASC 820-10-50-6A. Provide us with your
proposed disclosures.

3.       We note your response to prior comment 6 and that approximately $9
million or 77% of
         unrealized losses of $11,738,163 for the six months ending June 30,
2020 related to one
         equity security classified as a Level 1. We also note that excluding
Level 3 equity
         security sales of $10,450,468, that remaining common stock sales for
Levels 1 and 2 were
         $5,736,337 for the six months ending June 30, 2020 based on activity
disclosed in the
         statement of cash flows and that, based on your original Level 3
rollforward disclosure on
         page 16 of your June 30, 2020 Form 10-Q depicting no realized gains or
losses, your
         realized gains of $8,615,617 related to Levels 1 and 2 investments.
Considering the
         significant unrealized losses related to one security and the
significant gain on equity
         securities sold, please address the following:

                Given that your proposed revised disclosure in Exhibit C of
your response indicates
              that the $139,588 loss recognized during the first six months of
2020 includes both
              realized and unrealized gains/losses, tell us how much of the
$8,615,617 total realized
              gains on equity securities relates to Level 3 investments at fair
value and your
              investments carried at net asset value;
                Tell us the circumstances that resulted in a realized gain of
$8,615,617 and how you
              calculated those gains, including the nature of the underlying
investments;
                Tell us why it is appropriate to disclose realized investment
gains or losses for your
              investments in equity securities when ASC 321-10-40-1 indicates
that the sale of an
              equity security does not necessarily give rise to a gain or loss
given that all changes
              in an equity security's fair value are reported in earnings as
they occur;
                Tell us how your proposed disclosure provides the information
required by ASC 321-
              10-50-4 of:
                o   Net gains and losses recognized during the period on equity
securities; less
                o   Net gains and losses recognized during the period on equity
securities sold
 Jesse Correll
UTG, Inc.
September 30, 2020
Page 3

                   during the period; resulting in
                 o Net unrealized gains and losses recognized during the period
on equity
                   securities still held at the end of the period; and
                Tell us and disclose in future filings, vulnerabilities due to
concentrations of your
              investments, including individual holdings relative to the total
carrying value of your
              equity securities. Refer to ASC 275-10-50.

         Provide us with your proposed disclosure. In your response, separately
provide us a
         rollforward of your equity securities investments from December 31,
2019 through June
         30, 2020 that separately depicts those in Level 1, Level 2, Level 3
and carried at net asset
         value. In the rollforward separately present:

                The balances at December 31, 2019;
                Investment purchases (the total of which tying to the amount
presented in your cash
              flow statement);
                Investment sales (the amount of which tying to the amount
presented in your cash
              flow statement);
                Realized gains/losses;
                Unrealized gains/losses;
                Any transfers between Levels in the fair value hierarchy or
carried at net asset value;
              and
                The balances at June 30, 2020.

       You may contact Michelle Miller at 202-551-3368 or Mark Brunhofer at
202-551-3638 if
you have questions.



FirstName LastNameJesse Correll                                 Sincerely,
Comapany NameUTG, Inc.
                                                                Division of
Corporation Finance
September 30, 2020 Page 3                                       Office of
Finance
FirstName LastName