November 18, 2020

VIA E-mail

Yolanda Lewis
Yolanda Lewis Innovative Resources Inc.
CEO, President
2752 21st Street
Sacramento, CA 95828

          Re: Yolanda Lewis File No. 811-23372

Dear Ms. Lewis:

         We have reviewed the registration statement for Yolanda Lewis, filed
on Form N-8B-4 with
the Securities and Exchange Commission on September 30, 2019. Our preliminary
review of your
filing indicates that it fails to comply with the requirements of the
Investment Company Act of 1940,
the related rules and regulations, and the requirements of the form. Because of
these serious
deficiencies, you should not assume that your filing may be relied upon for
compliance with the federal
securities laws. We urge you to promptly correct these deficiencies or
deregister i the investment
company created by this filing.





Sincerely,

                                                                           /s/
Deborah L. O   Neal


Deborah L. O   Neal

Senior Counsel

cc:     Keith A. OConnell, Branch Chief
        Michael J. Spratt, Assistant Director



               i
                 To deregister the investment company, submit a completed Form
N-8F, available at
               https://www.sec.gov/files/formn-8f.pdf. See also IM Guidance
Update 2014-05 - Deregistration
               of Investment Companies: Applications on Form N-8F (April 2014),
available at
               https://www.sec.gov/investment/im-guidance-2014-05.pdf.