SecProbe.io

United States securities and exchange commission logo
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

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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

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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.
Sincerely,
Division of Corporation Finance
Office of Finance