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INVESTMENT MANAGERS SERIES TRUST III

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

September 3, 2025

Mr. Kenneth Ellington

Mr. Christopher R. Bellacicco

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Division of Investment Management

 Re: Investment Managers Series Trust III (the “Registrant”)

Registration Statement on Form N-14
(File No. 333-289195)

Dear Mr. Ellington
and Mr. Bellacicco:

This letter summarizes the comments provided to
me by Mr. Kenneth Ellington of the staff of the Securities and Exchange Commission (the “Staff”) by telephone on August 12,
2025, and by Mr. Christopher R. Bellacicco of the Staff by telephone on August 25, 2025, on the Registrant’s registration statement
filed on Form N-14 (the “Registration Statement”) relating to the proposed reorganization of the Centerstone Investors Fund
(the “Acquired Fund”), a series of Northern Lights Fund Trust III, into the FPA Crescent Fund (the “Acquiring Fund”),
a series of the Registrant. The Acquired Fund and the Acquiring Fund are referred to herein as the “Funds.”

Responses to all of the comments are included
below and, as appropriate, will be reflected in the combined proxy statement and prospectus that will be filed via EDGAR on September
3, 2025. Capitalized terms not otherwise defined in this letter have the meanings assigned to them in the Registration Statement.

General

 1. The Staff reminds you that the Registrant and its management are responsible for the accuracy and adequacy
of its disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Please also respond to our comments
in writing and file as correspondence on EDGAR. Where a comment asks for revised disclosure or revisions are contemplated by your response,
please provide draft disclosure with your letter. Please allow the Staff sufficient time to review
the Registrant’s response prior to filing the 497 filing.

Response: The
Registrant acknowledges the comments and has addressed them accordingly.

Combined Information Statement/Prospectus

 2. Please confirm that the fees shown in the Fees and Expenses Tables represent current fees in accordance
with Item 3 of Form N-14.

Response:
The Registrant confirms that the fees and expenses presented represent current fees.

    1

 3. In the Fees and Expenses Tables, please move “Short Sale Dividend and Interest Expenses” to
a sub-caption of “Other Expenses” and remove “Other Expenses Before Short Sale Dividends and Interest Expenses”
and “Total Annual Fund Operating Expenses Before Short Sale and Dividend Expenses.”

Response:
The Registrant has revised the Fees and Expenses Tables as requested. Please see Appendix A attached.

 4. In the Example, please confirm the 10-year expense example figure for Class I shares of the Acquired Fund,
as the Staff calculates this to be $1,541 rather than $1,514.

Response:
The Registrant has revised the 10-year expense example figure to reflect $1,541. Please see Appendix A attached.

 5. Please confirm that any expenses of the Acquired Fund subject to recoupment will
not be subject to recoupment after the Reorganization.

Response:
The Registrant confirms that following the Reorganization FPA will not seek recoupment from the Acquiring Fund of fees waived or expenses
reimbursed by Centerstone to the Acquired Fund prior to the Reorganization.

 6. Please confirm if any expenses reimbursed by FPA to the Acquiring Fund will be subject to recoupment.

Response:
The Registrant confirms that FPA will not seek recoupment of any expenses reimbursed by FPA to the Acquiring Fund.

 7. Please include the financial highlights or incorporate by reference the financial highlights for the Acquired
Fund (see Item 6 of Form N-14).

Response:
The Registrant has revised the following disclosure:

The audited
financial statements of the Acquired Fund for the year ended March 31, 2025, are incorporated by reference into the Statement of Additional
Information relating to this Proxy Statement and have been audited by Cohen & Company, Ltd., an independent registered public accounting
firm, whose report thereon is included in the Acquired Fund’s Form
N-CSR for the fiscal year ended March 31, 2025. The Acquired Fund’s financial highlights have been derived from the Acquired
Fund’s financial statements, and are included in the Acquired Fund’s prospectus,
which is incorporated by reference herein.

The audited
financial statements of the Acquiring Fund are incorporated by reference into the Statement of Additional Information relating to this
Proxy Statement and have been audited by Tait, Weller & Baker LLP, an independent registered public accounting firm, whose report
thereon is included in the Acquiring Fund’s Form
N-CSR for the fiscal year ended December 31, 2024. The Acquiring Fund’s financial highlights are included in Appendix
D to this Proxy Statement.

    2

 8. The disclosure indicates that FPA expects to reposition a majority
of the holdings shortly after the Reorganization to align the portfolio. Please disclose the following: (i) an estimate of the percentage
of the Acquired Fund expected to be sold in connection with the Reorganization; (ii) the portfolio transaction costs that are expected
to be generated as a result of these trades; and (iii) the estimated impact to shareholders regarding capital gains distributions, including
dollars and per share amounts.

Response:  The Registrant
has revised the disclosure as follows:

FPA expects to reposition approximately
62% of the Acquired Fund’s investments after the Reorganization to align the portfolio with the Acquiring Fund’s strategies.
  The estimated cost of the repositioning is approximately $61,000 or less than $0.001 per share.  Based on the current market
value of the Acquired Fund’s holdings and their costs basis to the Acquired Fund, the Acquiring Fund anticipates realizing a
net loss on the repositioning, and, therefore, no net capital gains are expected to be realized in connection with the repositioning of
the Acquired Fund’s current portfolio.

 9. In the Notice and elsewhere in the combined proxy statement and prospectus, please revise IMST IIII to
be IMST III.

Response: The Registrant has
made the requested revisions.

 10. In question and answer “How will the proposed Reorganization affect the fees and expenses I pay
as a shareholder of the Acquired Fund?”, please bold the first sentence of the response. In addition, in the table contained in
the response, please add total annual fund operating expenses before short sales dividend and interest expenses and fee waiver/expense
reimbursements.

Response: The Registrant has
made the requested revision to the first sentence of the response. The Registrant has revised the tables in the response as follows:

The following tables show the total
annual fund operating expenses before and after short sale dividend and interest expense and any fee waiver and/or expense reimbursement
for each class of shares of the Acquired Fund, the Acquiring Fund, and the Pro Forma Combined Fund.

    Acquired

Fund – Class

    A Shares

    Acquiring

 Fund –

Investor Class Shares
    Pro Forma

 Combined

 Investor Class

 Shares

    Total Annual Fund Operating Expenses Before Short Sale Dividend and Interest Expenses and Fee Waiver/Expense Reimbursement
    1.56%
    1.27%
    1.27%

    Total Annual Fund Operating Expenses After Short Sale Dividend and Interest Expenses and Fee Waiver/Expense Reimbursement
    1.40%
    1.16%*
    1.16%*

    3

    Acquired

 Fund – Class

    C Shares

    Acquiring

 Fund –

Institutional

 Class Shares
    Pro Forma

 Combined

 Institutional

 Class Shares

    Total Annual Fund Operating Expenses Before Short Sale Dividend and Interest Expenses and Fee Waiver/Expense Reimbursement
    2.30%
    1.05%
    1.05%

    Total Annual Fund Operating Expenses After Short Sale Dividend and Interest Expenses and Fee Waiver/Expense Reimbursement
    2.15%
    1.06%*
    1.06%*

    Acquired

 Fund – Class

    I Shares

    Acquiring

 Fund – Supra

    Institutional

 Class Shares

    Pro Forma

 Combined

 Supra

 Institutional

 Class Shares

    Total Annual Fund Operating Expenses Before Short Sale Dividend and Interest Expenses and Fee Waiver/Expense Reimbursement
    1.30%
    1.05%
    1.05%

    Total Annual Fund Operating Expenses After Short Sale Dividend and Interest Expenses and Fee Waiver/Expense Reimbursement
    1.15%
    1.00%*
    1.00%*

*Includes 0.01% of
Short Sale Dividend and Interest Expenses.

 11. With respect to the question and answer “Who has an interest in the Reorganization?”, please
supplementally explain in your correspondence: (a) what “transition services” Centerstone is providing, (b) for how long FPA
will make such payments to Centerstone, and (c) whether there is any limit on the amount that FPA will pay to Centerstone. To the extent
that payments may continue in perpetuity, please explain how such an agreement is consistent with Section 17(e) of the 1940 Act.

Response: (a) The transition
services that will be provided by Centerstone include certain information and non-investment advisory services to FPA regarding portfolio
investments, specifically: (i) providing requested portfolio information about the Acquired Fund’s assets; (ii) providing assistance
for the preparation of the Acquiring Fund’s audited and unaudited financial statements, financial reporting and other 1940 Act reporting
requirements; and (iii) supporting FPA’s interaction with Acquired Fund shareholders. For clarity, Centerstone will not be serving
in any asset management, securities distribution or investment advisory capacity.

(b) FPA will make payments to Centerstone
for the transition services described above for a period of five years following the Reorganization completion date.

(c) During the five-year period, FPA
will pay Centerstone 60% of the net advisory fees and net administrative services fee received by FPA from the Acquiring Fund with respect
to the net asset value of the Acquired Fund immediately prior to the Closing Date.

    4

 12. The introductory language under the section “Purchase, Redemption and Valuation Procedures”
indicates that additional information about the Acquiring Fund is contained in Appendix B. Is the information complete with respect to
the Acquired Fund? Please consider revising the disclosure to add clarity for shareholders.

Response: The information contained
in the comparison table is intended to provide a brief summary to shareholders. The Registrant has added the following disclosure:

Additional information regarding the
pricing, purchase and redemption of the Acquired Fund’s shares is included in the Acquired Fund’s prospectus
which is incorporated by reference into this Proxy Statement.

Proxy Card

 13. Please revise to bold the text indicating the proxy is solicited on behalf of the Fund’s Board of
Trustees, consistent with Rule 14A-4(a)(1) under the Securities Exchange Act of 1934, as amended.

Response: The Registrant has
revised the disclosure as requested.

* * * * *

The Registrant believes that it has fully responded
to each comment. If, however, you have any further questions or require further clarification of any response, please contact me at (626)
385-5777. I may also be reached at diane.drake@mfac-ca.com.

Sincerely,

/s/ Diane J. Drake

Diane J. Drake

Secretary

    5

Appendix A – Fees and Expense Tables and
Examples

Acquired Fund - Class A Shares/Acquiring Fund – Investor
Class Shares

    Shareholder Fees

(fees paid directly from your investment)

    Acquired

Fund

Class A

    Acquiring

 Fund

Investor

Class

    Pro Forma

Combined

    Investor

    Class

    Maximum Sales Charge (Load) Imposed on Purchases (as a percentage of offering price)

    5.00%

    None

    None

    Maximum Deferred Sales Charge (Load)

    1.00%1

    None

    None

    Annual Fund Operating Expenses

(expenses that you pay each year as a percentage of the value of your investment)

    Management Fees

    0.90%

    1.00%2

    1.00%2

    Distribution and Service (Rule 12b-1) Fees

    0.25%

    None

    None

    Other Expenses

    0.36%

    0.28%

    0.28%6

    Shareholder Service Fee
    0.00%

    0.25%

    0.25%

    Short Sale Dividend and Interest Expense
    0.00%

    0.01%

    0.01%

    All Other Expenses
    0.36%

    0.02%

    0.02%

    Acquired Fund Fees and Expenses3

    0.05%

    0.00%

    0.00%6

    Total Annual Fund Operating Expenses

    1.56%

    1.28%

    1.28%6

    Fee Waiver/Expense Reimbursement

    (0.16)%4

    (0.12)%5

    (0.12)%5

    Total Annual Fund Operating Expenses After Fee Waiver/Expense Reimbursement

    1.40%4

    1.16%5

    1.16%5,6

 1 A maximum contingent deferred sales charge (“CDSC”) of 1.00% may apply to certain redemptions
of Class A shares made within the first 18 months of their purchase when an initial sales charge was not paid on the purchase.

 2 The Acquiring Fund’s “Management Fees” include both the
advisory fee of 0.93% and class-specific administrative service fee of 0.07%.

 3 This number represents the combined total fees and operating expenses of the acquired funds owned by the
Fund and is not a direct expense incurred by the Fund or deducted from the Fund’s assets. Since this number does not represent a
direct operating expense of the Fund, the operating expenses set forth in the Fund’s financial highlights do not include this figure.

 4 Centerstone has contractually agreed to waive its fees and reimburse expenses of the Acquired Fund, at
least until August 1, 2027 so that the Total Annual Operating Expenses After Fee Waiver and Reimbursement (but does not include: (i) any
front-end or contingent deferred loads; (ii) brokerage fees and commissions; (iii) acquired fund fees and expenses; (iv) borrowing
costs (such as interest and dividend expense on securities sold short); (v) taxes; and (vi) extraordinary expenses, such as litigation
expenses (which may include indemnification of Fund officers and Trustees, contractual indemnification of Fund service providers (other
than the advisor))) will not exceed 1.35% of average daily net assets attributable to Class A shares. These fee waivers and expense reimbursements
are subject to possible recoupment from the Acquired Fund within three years after the fees have been waived or reimbursed, if such recoupment
can be achieved within the lesser of the foregoing expense limits or the expense limits in place at the time of recoupment. This agreement
may be terminated by the Board of Trustees, on behalf of the Acquired Fund, only on 60 days’ written notice to Centerstone or upon
termination of the advisory agreement between the Trust and Centerstone.

 5 FPA has contractually agreed to reimburse the Acquiring Fund for operating expenses in excess of 0.15%
of the average net assets of the Investor Class shares of the Acquiring Fund, excluding management fees, administrative service fees,
short sale dividend expenses and interest expenses on cash deposits relating to short sales, brokerage fees and commissions, redemption
liquidity service expenses, interest, taxes, fees and expenses of other funds in which the Acquiring Fund invests, and extraordinary expenses,
including litigation expenses not incurred in the Acquiring Fund’s ordinary course of business, for a period of two years from the
date of the Reorganization. FPA has also contractually agreed to reimburse the Acquiring Fund for redemption liquidity service expenses
in excess of 0.0044% of the average net assets of the Investor Class shares of the Acquiring Fund for a period of two years from the date
of the Reorganization. These agreements may only be terminated earlier by the Acquiring Fund’s board of trustees or upon termination
of the investment advisory agreement. Total Annual Operating Expen