April 10, 2019 Anthony J. Iarocci, Jr. Chief Executive Officer DCA Asset Management, Inc. 8217 East Spanish Boot Road Carefree, Arizona 85377 Re: DCA Asset Management, Inc. Registration Statement on Form 10-12G and 10-12G/A Filed January 3, 2019 and January 10, 2019 File No. 000-54966 Dear Mr. Iarocci: We issued comments on the above captioned filing on February 12, 2019. On March 21, 2019 we issued a follow-up letter informing you that those comments remained outstanding and unresolved, and absent a substantive response, we would act consistent with our obligations under the federal securities laws. As you have not provided a substantive response, we are terminating our review and will take further steps as we deem appropriate. These steps include releasing publicly, through the agency's EDGAR system, all correspondence, including this letter, relating to the review of your filing, consistent with the staff s decision to publicly release comment and response letters relating to disclosure filings it has reviewed. Please contact Gregory Dundas, Attorney-Advisor, at (202) 551-3436 or Larry Spirgel, Assistant Director, at (202) 551-3810 with any questions. Sincerely, Division of Corporation Finance Office of Telecommunications cc: Elaine Dowling, Esq.