SecProbe.io

January 7, 2020
Tony Nick
Chief Executive Officer
Clancy Systems International, Inc.
2250 S. Oneida, #308
Denver, Colorado 80224
Re:Clancy Systems International, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2019
Filed December 16, 2019
File No. 033-04882-D
Dear Mr. Nick:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response, we may have additional comments.
Form 10-K for the Fiscal Year Ended September 30, 2019
General
1.Please amend your filing to address the following:

•Ensure that your financial statements and related footnote disclosures have been
prepared and audited in accordance with generally accepted accounting principles.
Refer to Rule 8-02 of Regulation S-X.  For instance, we note that your Statement of
Operations and Other Comprehensive Loss shows no amounts for fiscal 2019, and
other than cash and cash equivalents, your Balance Sheet amounts remain unchanged
from September 30, 2018 to 2019.  At a minimum, these statements should be
impacted by depreciation and amortization related to your property and equipment
and intangible assets.
•Include a report of your independent registered public accounting firm pursuant to
Rule 2-02 of Regulation S-X and ensure that your auditors meet the requirements of
Rule 2.01 of Regulation S-X.  In this regard, we note the report of Causey Demgen

 FirstName LastNameTony Nick
 Comapany NameClancy Systems International, Inc.
 January 7, 2020 Page 2
 FirstName LastName
Tony Nick
Clancy Systems International, Inc.
January 7, 2020
Page 2
& Moore in your September 30, 2017 Form 10-K states that such firm is not
independent with respect to the company.
•Include a discussion of your results of operations and liquidity.
•The evaluation of your disclosure controls and procedures and internal control over
financial reporting should be as of the end of the period covered by the report.  In this
regard, you appear to have concluded on disclosure controls and procedures as of
September 30, 2008 and internal control over financial reporting as of September 30,
2017.  Please revise. Refer to Item 307 and 308 of Regulation S-K.
•You should provide a separate certification for both your principal executive officer
and principal financial officer.  If Mr. Nick served as both the principal executive
officer and principal financial officer, please revise to clearly indicate that he is
certifying in both capacities. Refer to Exhibit 31 and 32 of Regulation S-K and
Sections 302 and 906 of the Sarbanes-Oxley Act of 2002.
            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 Eiko Yaoita Pyles, Staff Accountant at (202) 551-3587 or Kathleen
Collins, Accounting Branch Chief at (202) 551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology