May 8, 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.
           Amendment No. 3 to Registration Statement on Form 10-12G
           Filed April 29, 2019
           File No. 000-54966

Dear Mr. Iarocci:

       We have reviewed your amended filing 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 10-12G/A filed April 10, 2019

Risk Factors
Risks Related to our Business, page 9

1.    We are unable to locate any additional disclosure in response to our
prior comment 3. As
      previously requested, please expand your risk factor discussion to
highlight the possibility
      of undisclosed liabilities stemming from your previous existence as a
public company
      prior to the revocation of your Securities Exchange Act of 1934
registration.
Management's Discussion and Analysis of Financial Condition , page 20

2.    We are unable to locate any additional disclosure in response to our
prior comment 5. As
      previously requested, please discuss your plan of operation in the form
of milestones,
      indicating the specific steps needed to make the company operational and
generating
      revenues, the timing of those steps in weeks, months, or quarters, the
costs, the source of
      funds and the expected date of first sales. Explain clearly what steps
you have taken to
 Anthony J. Iarocci, Jr.
DCA Asset Management, Inc.
May 8, 2019
Page 2
      date and which steps remain to be implemented.
Capital Resources and Liquidity, page 22

3.    We note your response to our prior comment 6. Please revise to clarify
what you mean by
      "current capital levels" and "expansion."
Security Ownership of Certain Beneficial Owners and Management, page 24

4.    We note your added disclosure in response to our prior comment 7. Please
revise your
      beneficial ownership table to separately list Anthony Iarocci, Jr., and
Michael Schnaus as
      beneficial owners, with their beneficial holdings reflecting the number
of shares that they
      each beneficially own through DuLac Capital Assets.
        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 Christie Wong, Staff Accountant, at (202) 551-3684 or
Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding the
financial statements and related matters. Please contact Gregory Dundas,
Attorney Advisor, at
(202) 551-3436 or Larry Spirgel, Assistant Director, at (202) 551-3810 with any
other questions.



                                                            Sincerely,
FirstName LastNameAnthony J. Iarocci, Jr.
                                                            Division of
Corporation Finance
Comapany NameDCA Asset Management, Inc.
                                                            Office of
Telecommunications
May 8, 2019 Page 2
cc:       Elaine Dowling, Esq.
FirstName LastName