SecProbe.io

February 5, 2020
Stephanie M. Risk-McElroy
President and Chairman of the Board
George Risk Industries, Inc.
802 South Elm St.
Kimball, Nebraska 69145
Re:George Risk Industries, Inc.
Form 10-K for the Fiscal Year Ended April 30, 2019
Filed August 13, 2019
File No. 000-05378
Dear Ms. Risk-McElroy:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Fiscal Year Ended April 30, 2019
Notes to the Financial Statements
Note 1. Nature of Business and Summary of Significant Accounting Policies
Revenue Recognition, page F-13
1.You disclose that you recognize product returns as they are received. Please explain to us
how this is consistent with the guidance in ASC 606-10-55-22 through 29, or revise your
future filings to clearly disclose your compliance with that guidance. Tell us the amount of
product returns you recorded in fiscal 2019 and in the six months ended October 31, 2019,
and briefly describe to us how you accounted for these product returns transactions (e.g.,
the accounts you debited and credited).

 FirstName LastNameStephanie M. Risk-McElroy
 Comapany NameGeorge Risk Industries, Inc.
 February 5, 2020 Page 2
 FirstName LastName
Stephanie M. Risk-McElroy
George Risk Industries, Inc.
February 5, 2020
Page 2
Note 3. Investments, page F-17
2.We note that your investments in equity securities represent 49% of your total assets at
October 31, 2019 and that they are classified as available-for-sale securities and reported
at fair value with unrealized gains and losses reported in other comprehensive
income. Please tell us why you have not yet adopted ASU 2016-01 - Recognition and
Measurement of Financial Assets and Financial Liabilities, and the related guidance in
ASC 321 - Investments-Equity Securities, which were effective for public companies like
yours for fiscal years beginning after December 15, 2017 (i.e., your fiscal year beginning
May 1, 2018). Provide us with a quantified discussion of the impact on your financial
statements and related disclosures for the year ended April 30, 2019 and for the six
months ended October 31, 2019, had you adopted the standard on May 1, 2018.
            In closing, 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.
            You may contact Andi Carpenter at 202-551-3645 or Martin James, Senior Advisor, at
202-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing