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Investment
Managers Series Trust III

235
W. Galena Street

Milwaukee,
Wisconsin 53212

VIA EDGAR

November 8, 2024

Ms. Kim McManus

U.S. Securities and
Exchange Commission

Division of Investment
Management

100 F Street, NE

Washington, DC 20549

 Re: Investment
                                            Managers Series Trust III (the “Registrant” or “Trust”) (File Nos.
                                            033-79858 and 811-08544) on behalf of the Manteio Managed Futures Strategy Fund and Manteio
                                            Multialternative Strategy Fund

Dear
Ms. McManus:

This
letter summarizes the comments provided to me by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) by telephone on October 3, 2024, regarding Post-Effective Amendment No. 121 to the Registrant’s registration
statement filed on Form N-1A (the “Registration Statement”) on August 19, 2024, relating to the Manteio Managed Futures Strategy
Fund and Manteio Multialternative Strategy Fund, each a newly created series of the Registrant (each, a “Fund” and collectively,
the “Funds”).

Responses
to all of the comments are included below and, as appropriate, will be incorporated into a Post-Effective Amendment to the Funds’
Registration Statement (the “Amendment”) that will be filed separately. Capitalized terms not otherwise defined in this letter
have the meanings assigned to them in the Registration Statement.

GENERAL

 1. Please
                                            provide a representation confirming that shares of the Funds will not be sold on the Registration
                                            Statement until after the reorganization is consummated.

Response:
The Registrant represents that shares of the Funds will not be sold on the Registration Statement until after the reorganization
is consummated.

PROSPECTUS

Summary
Section – Manteio Managed Futures Strategy Fund

 2. The
                                            investment objective for the Manteio Managed Futures Strategy Fund’s investment objective
                                            states that the Fund, “…seeks to achieve investment results that correspond
                                            generally to the risk and return patterns of managed futures funds.” Please state the
                                            investment objective of the Fund in more plain English in accordance with Form N-1A.

Response:
The investment objective for the Manteio Managed Futures Strategy Fund has been revised as follows:

The
Manteio Managed Futures Strategy Fund (the “Fund”) seeks to achieve positive absolute returns that have low correlation
to the returns of broad stock and bond markets achieve investment results that correspond generally to the risk and return
patterns of managed futures funds.

    1

Fees
and Expenses of the Fund – Both Funds

 3. With
                                            respect to each of the Manteio Managed Futures Strategy Fund and the Manteio Multialternative
                                            Strategy Fund, please confirm in correspondence that the wholly owned Subsidiary’s
                                            management fee (including any performance fee), if any, will be included in the management
                                            fee line item.

Response:
The Registrant confirms that the Subsidiary of each Fund will not be charged a management fee or performance fee.

 4. For
                                            each Fund, in the footnote to the fees and expenses table that discusses the operating expense
                                            limitation agreement, please disclose the expected date of termination of that agreement.

Response:
The Registrant has revised the relevant disclosure in the footnote to the fees and expenses table for each Fund as follows:

This
agreement is in effect for a period of two years from the date of the Reorganization (i.e., through November 22, 2026), and it
may be terminated before that date only by the Trust’s Board of Trustees.

Principal Investment
Strategies – Both Funds

 5. Please
                                            disclose that the principal investment strategies and principal risk disclosures reflect
                                            aggregate operations of the Fund and the Subsidiary.

Response:
The Registrant has added disclosure to each Fund’s principal investment strategies as follows:

When
used in this Prospectus, the term “Fund” includes the Subsidiary and the term “invest” includes investments the
Fund makes directly and through the Subsidiary.

Principal Investment
Strategies – Manteio Managed Futures Strategy Fund

 6. The
                                            principal investment strategies for the Fund state that, “[t]he Fund may also obtain
                                            exposure to other strategies commonly used by managed futures funds.” Please elaborate
                                            on what you mean by the other strategies commonly used by managed futures funds.

Response:
The Registrant has revised the disclosure as follows:

The
Fund seeks diverse exposure to significant price trends, both up and down, across asset classes, geographies and time horizons. It
aims to capture the aggregate risk-return characteristics of the managed futures industry without the cost and complexity of a multi-manager
approach. The Fund may take long and/or short positions in asset classes, and the Fund’s advisor dynamically adjusts its
exposure to individual asset classes based on a trend-following approach. The Fund may also obtain exposure to other strategies
commonly used by managed futures funds. As a component of its overall investment process, the Fund’s advisor may utilize
certain quantitative models and methodologies to guide its investment approach or security selection although the use of such models
and methodologies may vary based on market factors and economic trends as determined by the advisor.

    2

Principal Investment
Strategies – Manteio Multialternative Strategy Fund

 7. Please
                                            disclose the maximum potential loss from writing uncovered calls.

Response:
The Registrant has added the following disclosure:

The
Fund may sell call options pursuant to which the purchaser pays the Fund a premium in exchange for the right to purchase the security
underlying the option at a specified price (the “strike price”) within a specified time period or at a specified future date.
The call options the Fund sells may either be covered (i.e., where the Fund holds the underlying security) or uncovered (i.e., where
the Fund does not hold the underlying security). The seller of an uncovered call option assumes the risk of a theoretically unlimited
increase in the market price of the underlying security above the strike price of the option, and thus the seller’s potential for
loss is unlimited.

 8. In
                                            the principal investment strategies, please explain what is meant by “directional and/or
                                            relative value strategies.” In addition, please explain and provide further details
                                            regarding the quantitative models and methodologies used by the Advisor and how their applications
                                            vary based on market environments and economic trends.

Response:
The Registrant has revised the first, second and third paragraphs under “Principal Investment Strategies” as follows:

The
Fund seeks to achieve pursues its investment objective by utilizing a macro-aware investment process to allocate
capital across a range of investment strategies. The Fund may invest in a broad range of instruments, including equities, American
Depositary Receipts (“ADRs”) and Global Depositary Receipts (“GDRs”), other mutual funds, exchange-traded funds
(“ETFs”), warrants, bonds (both investment grade and below investment grade (commonly referred to as “high yield securities”
or “junk bonds”)), currencies, commodities, futures, exchange-traded and over-the-counter put and call options (both covered
and uncovered) and total return and excess return swaps. The Fund may invest in such instruments directly or, in the case of commodities
and certain commodity-linked instruments, indirectly, by investing in its wholly-owned Subsidiary organized under the laws of the Cayman
Islands (as described below) which invests in such commodities and commodity-linked instruments. The Fund also may invest in cash and
cash equivalents. As a result of the Fund’s use of derivatives, the Fund may hold significant amounts of high-quality, short-term
securities, including U.S. Treasuries, shares of money market funds and repurchase agreements. The Fund may also invest in high-yield
securities to earn income, as well as to achieve its investment objective. The Fund may invest in bonds of any maturity and duration.
The Fund may invest globally (including in emerging markets) and there are no geographic limits on the Fund’s holdings.

The
Fund’s advisor primarily, but not exclusively, allocates the Fund’s assets to directional positions (i.e.,
positions that depend upon an up or down price movement in an instrument or market for success) and/or relative value positions
strategies (i.e., positions that depend on price relationships between various instruments or markets and
seek to profit from pricing inefficiencies) through that take long and/or short exposures positions
in instruments across all major asset classes. The instruments in which the Fund may invest may be U.S. dollar or non-U.S.
dollar denominated. The Fund may have exposure to issuers of any size and credit quality. The percentage of the Fund’s portfolio
exposed to an asset class and geographic region will vary from time to time. The Fund intends to engage in active and frequent trading.

    3

The
As a component of its overall investment process, the Fund’s advisor may utilizes a process-driven
approach that blends its proprietary quantitative techniques with disciplined oversight in an effort to deliver positive absolute returns.
The advisor’s investment process begins with statistical research and fundamental analysis of various investment strategies spanning
all major public markets. The advisor applies its proprietary quantitative models to arrive at a subset of liquid investment strategies
that the advisor believes are suitable for the Fund. These investment strategies include, among others, those that are Fundamental, which
focus on price and relative price determinants such as measures of carry (i.e., the yield differences between one instrument and
another) and appraisal of fair value, and Tactical, which focus on market structure and the behavior of market agents including lead-lag
effects (i.e., time dependent correlation relationships), liquidity provisioning and buffering, and positioning dynamics (i.e.,
exposure patterns or sensitivities). The advisor also employs macroeconomic and probabilistic modeling to guide its allocation decisions
and select investments that the advisor believes will promote the maintenance of a balanced and efficient Fund risk profile by explicitly
considering how the evolution of markets and the behavior of market participants impact the performance and interaction of strategies.
certain quantitative models and methodologies to guide its investment approach or security selection although the use of
such models and methodologies may vary based on market environments and economic trends as determined by the advisor.

The
Fund may invest globally (including in emerging markets) and there are no geographic limits on the Fund’s holdings. The instruments
in which the Fund may invest may be U.S. dollar or non-U.S. dollar denominated. The Fund may have exposure to issuers of any size and
credit quality. The Fund intends to engage in active and frequent trading.

The
percentage of the Fund’s portfolio exposed to an asset class and geographic region will vary from time to time. The Fund may invest
in a broad range of instruments, including equities, American Depositary Receipts (“ADRs”) and Global Depositary Receipts
(“GDRs”), other mutual funds, exchange-traded funds (“ETFs”), warrants, bonds (both investment grade and below
investment grade (commonly referred to as “high yield securities” or “junk bonds”)), currencies, commodities,
futures, exchange-traded and over-the-counter put and call options (both covered and uncovered) and total return and excess return swaps.
The Fund may invest in such instruments directly or, in the case of commodities and certain commodity-linked instruments, indirectly,
by investing in its wholly-owned Subsidiary organized under the laws of the Cayman Islands (as described below) which invests in such
commodities and commodity-linked instruments. The Fund also may invest in cash and cash equivalents. As a result of the Fund’s
use of derivatives, the Fund may hold significant amounts of high-quality, short-term securities, including U.S. Treasuries, shares of
money market funds and repurchase agreements. The Fund may also invest in high-yield securities to earn income, as well as to achieve
its investment objective The Fund may invest in bonds of any maturity and duration.

Principal Risks of
Investing – Manteio Multialternative Strategy Fund

 9. In
                                            the “Emerging Markets Risk” disclosure, please provide the Fund’s definition
                                            of emerging market countries.

Response:
The Registrant has added the following sentence to the Emerging Markets Risk disclosure:

The
Fund may invest in companies organized or doing substantial business in emerging market or developing countries, as defined by the World
Bank, International Finance Corporation, or included in any of the Morgan Stanley Capital International (MSCI) emerging market or other
comparable indices.

    4

Performance –
Both Funds

 10. Please
                                            inform the Staff what broad-based securities market index you plan to use for each Fund.

Response:
The Manteio Managed Futures Strategy Fund will compare its performance to the Bloomberg Global Aggregate Bond Index and the Manteio Multialternative
Strategy Fund will compare its performance to the Bloomberg US Aggregate Bond Index.

MORE
ABOUT THE FUNDS’ INVESTMENT OBJECTIVES, PRINCIPAL INVESTMENT STRATEGIES AND RISKS

Principal Investment
Strategies and Principal Risks – Both Funds

 11. Apply
                                            all applicable comments from the summary section for each Fund to Item 9 of Form N-1A.

Response:
The Registrant confirms that all applicable comments from the summary section for each Fund have been made to the Item 9 disclosure.

 12. The
                                            Staff notes that the Item 9 principal investment strategies disclosure for each Fund is nearly
                                            identical to that contained in the Fund’s Item 4 principal investment strategies disclosure.
                                            Item 4 is intended to be a summary; please revise as appropriate.

Response:
The Registrant has revised the summary sections as requested. The revised Item 4 principal investment strategies disclosure for each
Fund is contained in Appendix A attached hereto.

STATEMENT OF ADDITIONAL INFORMATION

 13. Under
                                            “Investments in the Subsidiary” please disclose that the investment advisor to
                                            the Subsidiary complies with the provisions of the Investment Company Act of 1940 Act, as
                                            amended (the “19