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                            November 19, 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 September 30, 2020
                                                            Filed November 13,
2020
                                                            File No. 000-16867

       Dear Mr. Correll:

              We have reviewed your October 14, 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
       September 30, 2020 letter.

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

       Notes to Consolidated Financial Statements
       Note 2. Investments

   1.                                                   We note your response
to prior comment 1. Please address the following:

                                                              Tell us if you
recognized, and are continuing to recognize, depreciation upon the
                                                            change in
classification from held for sale to held for investment in accordance with
                                                            ASC 360-10-35-44(a)
considering that it was not probable that these assets would be
                                                            sold within one
year as required by ASC 360-10-45-9(d);
                                                              If you did not
recognize depreciation on the former held for sale investments (either
 Jesse Correll
FirstName
UTG, Inc. LastNameJesse Correll
Comapany 19,
November   NameUTG,
               2020    Inc.
November
Page  2    19, 2020 Page 2
FirstName LastName
              the catch up depreciation upon reclassification to held for
investment purposes or
              normal recurring depreciation since reclassification), tell us
the amount of
              depreciation expense not recorded and provide us your SAB 99
analysis as to whether
              or not these amounts are material;
                Tell us why depreciation expense declined from $868,630 for the
nine months ended
              September 30, 2019 to $338,550 for the nine months ended
September 30, 2020; and
                Tell us why Investment real estate     commercial increased to
$5,415,238 at
              September 30, 2020 from $4,908,028 at December 31, 2019
considering you do not
              reflect any investment real estate purchases for the nine months
ended September 30,
              2020.
Note 3. Fair Value Measurements

2.       We note your response to prior comment 3 and that you separate
realized gains and
         market value changes in equity securities which together are reported
as net investment
         gains and losses within the income statement as you believe this
presentation helps the
         reader understand what is generating the amounts of net investment
gains (losses). Please
         address the following:

                Confirm that reported realized gains represents the difference
between the acquisition
              price and the sales price of investments sold and tell us the
acquisition prices and
              sales prices of the four equity securities sold as referenced in
your comment letter
              response;
                In future filings, please revise your disclosure to present
realized investment gains
              and losses as the difference between proceeds received upon sale
and the fair value at
              the transaction date consistent with the guidance in ASC
321-10-40-1. Note that you
              are not precluded from discussing cumulative realized gains and
losses from the date
              of acquisition in your Management Discussion and Analysis to
inform your investors
              of investment activity, including market fluctuations over time;
                In future filings, please revise your income statement
presentation to present gains
              and losses on equity security investments as the difference
between the fair value at
              the beginning of the period and the fair value at the reporting
date. Also revise your
              proposed disclosure in Exhibit D to your October 14, 2020 comment
letter response
              to calculate gains and losses as the difference between the fair
value at the beginning
              of the period versus the reporting date and or sale date, as
applicable, and
              characterize gains or losses as unrealized only on those
investments still held at
              period end consistent with the guidance in ASC 321-10-50-4;
                Tell us why in your September 30, 2020 Form 10-Q you reported
that the gain on
              music royalties sold during the first quarter of 2020 was
approximately $6.3 million
              upon sale whereas in your March 31, 2020 and June 30, 2020 Forms
10-Q you
              reported this amount as approximately $4.1 million and
approximately $4.2 million,
              respectively;
                Your proposed disclosure in Exhibit E states that you have
concentration risk within
              investments in the oil and gas industry. Please also disclose
whether you have any
 Jesse Correll
UTG, Inc.
November 19, 2020
Page 3
              concentrations relative to individual holdings that are
significant to your respective
              investment portfolios; and
                Please disclose in future filings, your oil and gas investments
by industry type and
              balance sheet classification as provided in Exhibit A to your
September 3, 2020
              comment letter response.

       You may contact Michelle Miller at 202-551-3368 or Mark Brunhofer at
202-551-3638 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameJesse Correll                                 Sincerely,
Comapany NameUTG, Inc.
                                                                Division of
Corporation Finance
November 19, 2020 Page 3                                        Office of
Finance
FirstName LastName