United States securities and exchange commission logo
July 29, 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 March 31, 2020
Filed May 12, 2020
File No. 000-16867
Dear Mr. Correll:
We have reviewed your 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 10 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 December 31, 2019
Note 3. Fair Value Measurements
1. You disclose in Note 4
of your March 31, 2020 Form 10-Q that equity securities classified
as Level 3 within the
fair value hierarchy include collateralized debt obligations of trust
preferred securities
issued by banks and insurance companies and certain equity securities
with unobservable
inputs. You also disclose in your Results of Operations discussion in
Management's Discussion
and Analysis in your Form 10-K that a significant portion of
unrealized gains are
from two equity holdings, both in the area of oil and gas, and
otherwise disclose that
you own a variety of investments associated with the oil and gas
industry and that these
investments represent approximately 19% and 25% of total
invested assets as of
March 31, 2020 and December 31, 2019. Please address the
following:
Jesse Correll
UTG, Inc.
July 29, 2020
Page 2
Tell us your basis for classifying collateralized debt
obligations as equity securities;
Disclose in future filing, quantitative information about the
significant unobservable
inputs used in the fair value measurement of equity securities
categorized as Level
3. Refer to ASC 820-10-50-2-bbb(2); and
Disclose in future filings, a narrative description of the
uncertainty of the fair value
measurements from the use of significant unobservable inputs if
those inputs
reasonably could have been different at the reporting date. Refer
to ASC 820-10-50-
2-g.
Provide us with a draft of your proposed disclosures as of March 31,
2020.
Notes to Consolidated Financial Statements
Note 2. Investments
2. You disclose that you own a variety of investments associated with the
oil and gas
industry and that these investments represent approximately 25% of
total investments at
December 31, 2019. Please tell us and provide us proposed disclosure
to be provided in
future filings that indicates the nature of your oil and gas
investments, including your
accounting and classification. For example, clarify if your
investments are in midstream
activities such as processing, storage, transporting, marketing of
oil, natural gas and
natural gas liquids or in upstream extraction activities. Separately
reference for us the
authoritative literature you rely upon to support your accounting and
classification.
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 Michelle Miller at 202-551-3368 or Mark Brunhofer at
202-551-3638 if
you have any questions.
FirstName LastNameJesse Correll Sincerely,
Comapany NameUTG, Inc.
Division of
Corporation Finance
July 29, 2020 Page 2 Office of
Finance
FirstName LastName