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April 27, 2020

Sonny Oh

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:	Northern
Lights Fund Trust; File Nos. 333-122917, 811-21720

Dear Mr. Oh:

On February 21, 2020, Northern
Lights Fund Trust (the “Trust” or the “Registrant”) filed a Registration Statement under the Securities
Act of 1933 and the Investment Company Act of 1940 (the “1940 Act”) on Form N-1A on behalf of PFG BNY Mellon®
Diversifier Strategy Fund, PFG JP Morgan® Tactical Aggressive Strategy Fund, PFG JP Morgan® Tactical Moderate Strategy
Fund, PFG Meeder Tactical Strategy Fund, PFG MFS® Aggressive Growth Strategy Fund, PFG Balanced Strategy Fund, PFG Equity Strategy
Fund, PFG Global Strategy Fund, PFG Active Core Bond Strategy Fund, and PFG Diversifier Strategy Fund (each a “Fund”,
and collectively, the “Funds”). In a telephone conversation on April 8, 2020 you provided comments to the Registration
Statement and Thompson Hine LLP (“Thompson Hine”). Below, please find a summary of those comments and the Registrant’s
response.

Cover

 1. Comment: Please revise the Rule 30e-3 legend to comply with Rule 30e-3 of the 1940 Act.

Response: You may elect
to receive all future reports in paper free of charge. You can inform the Fund or your financial intermediary that you wish to
continue receiving paper copies of your shareholder reports by calling 1-888-451-TPFG. Your election to receive reports in paper
will apply to all funds held with the fund complex.

General

 2. Comment: Please complete each Fund’s expense example.

Response: The Registrant
will ensure that each Fund’s expense example is complete in its next post-effective amendment.

 3. Comment: Please provide additional disclosure about each Fund’s allocation in its
respective underlying funds and the types of assets that the underlying funds invest in. If a Fund invests in fixed income securities,
please disclose the types of fixed income securities rather than the types of issuers.

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Response: The Registrant
has made the requested revisions.

 4. Comment: With regard to the disclosure “Pacific Financial Group, LLC (the “Adviser”)
may also invest in … that invest in equity securities of varying market capitalization, style, sector, and country exposure;
liquid alternative/specialty securities” – please provide a plain-english explanation of liquid alternative/specialty
securities.

Response: The Registrant
has revised the disclosure to remove any references to liquid alternative/specialty securities.

 5. Comment: Please reconcile the disclosure “The Fund … without regard to style
or sector exposure.” with the Fund’s Sector Risk disclosure that states, “The Fund may focus its investments
in securities of a particular sector”.

Response: The investment
strategy disclosure has been revised as follows:

The Fund pursues a strategy of
long-term growth, by investing in Underlying Funds that invest primarily in U.S. equity securities of any market capitalization.,
without regard any particular style or sector exposure.

 6. Comment: With regard to the disclosure – “The information provided includes
data and analysis about the … and the methodology used in selecting securities …” – please clarify the
types of data and analysis that the Underlying Funds use for selecting securities.

Response: The Registrant
has revised the existing disclosures to provide a more detailed description of each Fund’s investment strategies.

 7. Comment: Please clarify whether the Funds’ Adviser uses Rational Analysis to select
individual securities or underlying funds.

Response: The Registrant
declines to revise the current disclosure because the current disclosure states that the Adviser’s proprietary investment
analysis is used to select each Fund’s Underlying Funds.

 8. Comment: With regard to the disclosure, “the Adviser seeks to integrate the optimal
elements of each method into a “Rational” decision-making model.” – please revise to provide a plain-english
definition and describe the optimal elements of each method.

Response: The disclosure
has been added:

“Rational Analysis”
is the Adviser’s proprietary investment research process whereby the Adviser integrates the optimal elements of Fundamental
Analysis, Technical Analysis and Quantitative Analysis into a “Rational” decision-making model, in selecting Underlying
Funds for the Fund.

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•Technical Analysis is a
method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical
analysis uses charts and other tools to identify patterns that can suggest future activity of a security. The use of charts and
patterns to forecast future market activity is a different approach than a fundamental analysis of a security, which seeks to measure
the intrinsic value of a security. The Adviser uses Technical Analysis as an important factor in determining whether to sell securities.

•Fundamental Analysis is
a method of evaluating a security by attempting to measure the intrinsic value of a security, by examining economic, financial
and other qualitative and quantitative factors. Fundamental analysis attempts to examine all of the factors that can affect the
value of a security, including macroeconomic factors (like the overall economy and industry conditions) and factors specific to
an individual security (such as the financial condition and management of a company). Fundamental analysis is an essential factor
in making decisions to buy a security, as the analysis can reveal weaknesses or limits in a technical analysis or a quantitative
analysis of a security.

•Quantitative Analysis: The
Adviser uses mathematic analytics and quantitative modeling of a security. The mathematical and statistical calculations include
an analysis of Beta, standard deviation, Sharpe ratios, among others. A quantitative analysis is useful in providing another perspective
on how to view the value of a security and, because the analysis is driven by quantitative calculations, the analysis removes the
emotion from the decision-making process.

The Adviser believes that each
approach provides useful information about the value, or likely future performance, of a security (or, a portfolio of securities).
Rather than relying solely on one approach, the Adviser seeks to blend together the most useful information from each approach
(depending on a particular security, or a specific portfolio of securities) into what the Adviser believes is a “Rational”
approach to investment decision making.

 9. Comment: Comment. With regard to the disclosure “Further, in managing the Fund’s
level of investment risk, the Adviser utilizes RiskPro®, a software technology developed by ProTools, LLC …” –
please clarify whether the RiskPro software is used to monitor a Fund’s portfolio or the Underlying Funds.

Response: The Registrant’s
disclosure regarding the Funds’ use of RiskPro has been revised as follows:

Further, in managing the Fund’s
level of investment risk, the Adviser utilizes RiskPro®, a software technology developed by ProTools, LLC, an affiliate
of the Adviser. Based on proprietary algorithms, RiskPro® provides an estimate of the range of gain or loss of a
portfolio of securities over a forward-looking rolling twelve-month period. The higher the RiskPro estimate, the greater the level
of volatility that the Fund may experience over a twelve-month period. As a result, investors may select investments that are designed
to be aligned with their level of comfort with investment risk. RiskPro’s algorithms® take into account, among
other factors, the volatility of the portfolio over the prior twelve months; a comparison of the portfolio’s volatility over
the

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prior twelve-month period, to
the volatility of the S&P 500 Index; and the long-term volatility of the S&P 500 Index.

The Adviser utilizes RiskPro to
manage the Fund’s volatility as a whole, and to assess the impact of the Fund’s investment in Underlying Funds. The
Adviser does not, however, use RiskPro to identify specific Underlying Funds (or individual securities) in which to invest, on
behalf of the Fund. For this Fund, the Adviser’s goal is to limit the Fund's maximum annual volatility range of total returns,
over a twelve-month period, as estimated by RiskPro, to a gain or loss of less than [ ]%.

 10. Comment: With regard to the disclosure “The Fund is designed for investors that are
not willing to endure an amount of investment risk comparable to, or greater than, the volatility of the S&P 500” –
please revise to provide the volatility value of the S&P 500.

Response: The Registrant
has deleted the referenced disclosure.

 11. Comment: The Staff’s position on risk disclosures for the past several years has been
to disclose risks in the order of significance or prominence to the fund’s strategy. Disclosing risks in alphabetical order
suggests that each are equally imminent, whereas the risk disclosures should give shareholders which risks are of greater concern
or salient to each Fund. Pursuant to remarks from Dalia Blass, Director of the Division of Investment Management, please re-order
the Fund’s principal risk disclosures so that they appear in order of materiality (from most material to least) in lieu of
disclosing them in alphabetical order. See ADI 2019-08, “Improving Principal Risks Disclosure.”

Response: The Registrant
has given the Staff’s position, as well as Ms. Blass’s remarks and ADI 2019-08, thoughtful consideration. The Registrant
respectfully declines to re-order the Fund’s risk disclosures as requested. The materiality of each risk is fluid, i.e.,
what is the most material risk today may not be the most material risk tomorrow. Therefore, the Registrant believes that emphasizing
one risk over another may be misleading to investors.

 12. Comment: Please provide the corresponding risk disclosure for each Fund’s investments
in specialty investments.

Response: The Registrant
has deleted all references to investments in specialty investments.

 13. Comment: Please provide the corresponding risk disclosure for each Fund’s investments
in exchange traded funds.

Response: The Registrant
has added the following disclosure:

Exchange Traded Funds Risk.
The cost of investing in the Fund will be higher than the cost of investing directly in the ETFs in which it invests and may be
higher than other mutual funds that

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invest directly in stocks and
bonds. Each ETF is subject to specific risks, depending on the nature of the ETF.

 14. Comment: With regard to the liquid alternative securities risk, please revise the disclosure
by specifying the types of securities that exhibit low risk to modest correlation with traditional stock and bond investments.

Response: The Registrant
has deleted any reference to the Funds’ investments in liquid alternative securities.

 15. Comment: The Staff notes that significant market events due to the Coronavirus have occurred
since post-effective amendment was filed. Please consider whether a Fund’s disclosure including risk disclosures should be
revised based on how these events are effecting the markets for fixed income and equity securities. If the Funds believe that no
additional disclosure is warranted please explain supplementally why no additional disclosure is warranted.

Response: The Registrant
has added the following disclosure:

Market and Geopolitical Risk.
The increasing interconnectivity between global economies and financial markets increases the likelihood that events or conditions
in one region or financial market may adversely impact issuers in a different country, region or financial market. Securities in
the Fund’s portfolio may underperform due to inflation (or expectations for inflation), interest rates, global demand for
particular products or resources, natural disasters, pandemics, epidemics, terrorism, regulatory events and governmental or quasi-governmental
actions. The occurrence of global events similar to those in recent years may result in market volatility and may have long term
effects on both the U.S. and global financial markets. The current novel coronavirus (COVID-19) global pandemic and the aggressive
responses taken by many governments, including closing borders, restricting international and domestic travel, and the imposition
of prolonged quarantines or similar restrictions, as well as the forced or voluntary closure of, or operational changes to, many
retail and other businesses, has had negative impacts, and in many cases severe negative impacts, on markets worldwide. It is not
known how long such impacts, or any future impacts of other significant events described above, will or would last, but there could
be a prolonged period of global economic slowdown, which may impact your Fund investment.

 16. Comment: With regard to the Portfolio Managers disclosure – please consider revising
the disclosure to state the month that the Portfolio Managers began serving each Fund.

Response: The disclosure
has been revised:

Jennifer Enstad, CFA®, Chief
Investment Officer and Eric Neufeld, CFA®, Portfolio Manager have each served the Fund as a portfolio manager since it commenced
operations in December 2017. Each Portfolio Manager is jointly and primarily responsible for the day to day management of the Funds.

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 17. Comment: With regard to the Tax Information disclosure – the Staff notes that the
Fund shares are available for purchase by all investors. Please revise the tax information disclosure to discuss the distributions
to all types of investors.

Response: The Registrant
has added the following disclosure:

For taxable investors, dividends
and capital gain distributions may be subject to federal income tax.

PFG BNY Mellon Diversifier Strategy
Fund

 18. Comment: The Staff notes that the Fund will invest at least 80% of its net assets in ETFs,
mutual funds, and other types of investments. Please explain how the Fund will achieve a diversifying strategy.

Response: The Registrant
notes that the Fund’s diversifying strategy is achieved through the Adviser’s decisions to allocate the Fund’s
investment exposure across various asset classes including fixed income instruments of various maturities and credit qualities
as well as equity exposure. The Fund’s portfolio is further diversified as a result of it implementing these asset class
exposures through investment in other registered investment companies.

 19. Comment: The Staff notes that the Fund will invest in underlying funds that invest in companies
of varying market capitalizations. Please provide the corresponding risk disclosures for investments in mid and large capitalization
companies.

Response: The following
disclosures have been added:

Mid Capitalization Stock Risk.
The Fund’s investments in the Underlying Funds may expose the Fund to risks involved in investing in medium capitalization
companies. The earnings and prospects of medium sized companies are more volatile than larger companies and may experience higher
failure rates than larger companies. Mid sized companies normally have a lower trading volume than larger companies, which may
tend to make their market price fall more disproportionately than larger companies in response to selling pressures and may have
limited markets, product lines, or financial resources and lack management experience.

Large Capitalization Stock
Risk. The Fund’s investments in the Underlying Funds may expose the Fund to risks involved in investing in large capitalization
companies. Large-capitalization companies may be less able than smaller capitalization companies to adapt to changing market conditions.
Large-capitalization companies may be more mature and subject to more limited growth potential compared with smaller capitalization
companies. During different market cycles, the performance of large capitalization companies