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CORRESP
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August 5, 2025

Kalkidan Ezra

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

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

Dear Ms. Ezra,

On July 11, 2025, Northern
Lights Fund Trust (the “Trust” or the “Registrant”), on behalf of its series, Altegris Futures Evolution Strategy
Fund, Princeton Premium Fund, Princeton Adaptive Premium Fund, Deer Park Total Return Credit Fund, and Eagle Energy Infrastructure Fund
(each a “Fund” and collectively the “Funds”), filed preliminary proxy statements pursuant to Section 14(a) of
the Securities Exchange Act of 1934 (the “Proxy Statements”).

You provided oral comments
to Joseph Faia with respect to the Proxy Statements. Please find below the Funds’ response to those comments, which the Registrant
has authorized Thompson Hine LLP to make on its behalf.

General

(All Funds)

Comment 1: We remind you that the Trust and
its management are responsible for the accuracy and adequacy of their disclosures, not withstanding any review, comment, action, or absence
of action by the Staff.

Response:	The Registrant so acknowledges.

Comment 2: Where a comment is made in one location
it is applicable to all similar disclosures appearing elsewhere in the registration statement. Please ensure that corresponding changes
are made to all similar dislcosures.

Response: 	The Registrant so acknowledges.

Comment 3: Please provide your response to
the Staff’s comments on EDGAR at least five business days of the effective date. Please also send me notice by email at EzraKal@sec.gov
and include a redline copy showing changes from the initial filing.

August 5, 2025

Page 2

Response:	The Registrant so acknowledges.

Comment 4: Please update the proxy statements
with any missing or incomplete information in the shareholder letter, notice of special meeting, and proxy statement.

Response:	All incomplete or missing information
will be included before the definitive proxy statements are filed.

Altegris Futures Evolution Strategy Fund

Comment 5: Prior to mailing please ensure that the total number
of outstanding shares are disclosed.

Response: 	The Registrant has included a completed outstanding
shares table. Please see the revised proxy statement attached hereto.

As of the Record Date, the following numbers of shares
of beneficial interest of the Fund were issued and outstanding:

    Voting Securities Outstanding*

    Class A
    Class C
    Class I

    577,968
    259,400
    3,808,497

Comment 6: Consider reviewing and revising the address provided
under “Operation of the Fund” and also in the proxy card to reflect the correct address.

Response: 	The address has been revised to reflect the correct
address.

Princeton Premium Fund Princeton Adaptive Premium

Comment 7: Prior to mailing please ensure that the total number
of outstanding shares are disclosed.

Response: 	The Registrant has included a completed outstanding
shares table. Please see the revised proxy statement attached hereto.

As of the Record Date, there were the number of shares
of beneficial interest of each Fund issued and outstanding as set forth below:

August 5, 2025

Page 3

    Fund
    Shares Issued and Outstanding

    Princeton Premium Fund
    Class A Shares:394,179 and Class I Shares:25,654

    Princeton Adaptive Premium Fund
    Class A Shares:11 and Class I Shares:134,836

Comment 8: Please disclose that the Funds are in compliance with
the two conditions of the safe harbor of Section 15(f) of the Investment Company Act of 1940.

Response: 	The requested revision has been made. The following
disclosure has been added:

Section 15(f) of the 1940 Act

Because the Closing may be considered to result in
a change in control of the Adviser under the 1940 Act resulting in the termination (due to a deemed assignment) of the Former Advisory
Agreement, the Adviser intends for the Closing to come within the safe harbor provided by Section 15(f) of the 1940 Act, which permits
an investment adviser of a registered investment company (or any affiliated persons of the investment adviser) to receive any amount or
benefit in connection with a sale of an interest in the investment adviser that results in an assignment of an investment advisory contract,
provided that the following two conditions are satisfied.

First, an “unfair burden” may not be imposed
on the investment company as a result of the sale of the interest, or any express or implied terms, conditions or understandings applicable
to the sale of the interest. The term “unfair burden,” as defined in the 1940 Act, includes any arrangement during the two-year
period following the transaction whereby the investment adviser (or predecessor or successor adviser), or any “interested person”
of the adviser (as defined in the 1940 Act), receives or is entitled to receive any compensation, directly or indirectly, from the investment
company or its security holders (other than fees for bona fide investment advisory or other services), or from any person in connection
with the purchase or sale of securities or other property to, from or on behalf of the investment company (other than ordinary fees for
bona fide principal underwriting services). The Adviser has confirmed for the Board that the Closing will not impose an unfair burden
on the Funds within the meaning of Section 15(f) of the 1940 Act.

Second, during the three-year period following the
Closing, at least 75% of the members of the investment company’s board of trustees cannot be “interested persons” (as
defined in the 1940 Act) of the investment adviser (or predecessor adviser). At the present time, 66.7% of the Trustees are classified
as Independent Trustees, i.e., not interested persons of the Trust. The Board has committed to ensuring that at least 75% of the Trustees
would not be “interested persons” of the Adviser for a period of three years after the Closing.

August 5, 2025

Page 4

Deer Park Total Return Credit Fund

Comment 9: Prior to mailing please ensure that
the total number of outstanding shares are disclosed.

Response: 	The Registrant has included a
completed outstanding shares table. Please see the revised proxy statement attached hereto.

As of the Record Date, there were
the number of shares of beneficial interest of the Fund issued and outstanding as set forth below:

Comment 10: Please disclose that the Funds
are in compliance with the two conditions of the safe harbor of Section 15(f) of the Investment Company Act of 1940.

Response: 	The requested revision has been
made. The following disclosures has been added:

Section 15(f) of the 1940 Act

Because the Closing may be considered to result in
a change in control of the Adviser under the 1940 Act resulting in the termination (due to a deemed assignment) of the Former Advisory
Agreement, the Adviser intends for the Closing to come within the safe harbor provided by Section 15(f) of the 1940 Act, which permits
an investment adviser of a registered investment company (or any affiliated persons of the investment adviser) to receive any amount or
benefit in connection with a sale of an interest in the investment adviser that results in an assignment of an investment advisory contract,
provided that the following two conditions are satisfied.

First, an “unfair burden” may not be imposed
on the investment company as a result of the sale of the interest, or any express or implied terms, conditions or understandings applicable
to the sale of the interest. The term “unfair burden,” as defined in the 1940 Act, includes any arrangement during the two-year
period following the transaction whereby the investment adviser (or predecessor or successor adviser), or any “interested person”
of the adviser (as defined in the 1940 Act), receives or is entitled to receive any compensation, directly or indirectly, from the investment
company or its security holders (other than fees for bona fide investment advisory or other services), or from any person in connection
with the purchase or sale of securities or other property to, from or on behalf of the investment company (other than ordinary fees for
bona fide principal underwriting

August 5, 2025

Page 5

services). The Adviser has confirmed for the Board
that the Closing will not impose an unfair burden on the Funds within the meaning of Section 15(f) of the 1940 Act.

Second, during the three-year period following the
Closing, at least 75% of the members of the investment company’s board of trustees cannot be “interested persons” (as
defined in the 1940 Act) of the investment adviser (or predecessor adviser). At the present time, 66.7% of the Trustees are classified
as Independent Trustees, i.e., not interested persons of the Trust. The Board has committed to ensuring that at least 75% of the Trustees
would not be “interested persons” of the Adviser for a period of three years after the Closing.

Section 15(f) of the 1940 Act

Because the Closing may be considered to result
in a change in control of the Sub-Adviser under the 1940 Act resulting in the termination (due to a deemed assignment) of the Former Sub-Advisory
Agreement, the Adviser intends for the Closing to come within the safe harbor provided by Section 15(f) of the 1940 Act, which permits
an investment adviser of a registered investment company (or any affiliated persons of the investment adviser) to receive any amount or
benefit in connection with a sale of an interest in the investment adviser that results in an assignment of an investment advisory contract,
provided that the following two conditions are satisfied.

First, an “unfair burden” may not
be imposed on the investment company as a result of the sale of the interest, or any express or implied terms, conditions or understandings
applicable to the sale of the interest. The term “unfair burden,” as defined in the 1940 Act, includes any arrangement during
the two-year period following the transaction whereby the investment adviser (or predecessor or successor adviser), or any “interested
person” of the adviser (as defined in the 1940 Act), receives or is entitled to receive any compensation, directly or indirectly,
from the investment company or its security holders (other than fees for bona fide investment advisory or other services), or from any
person in connection with the purchase or sale of securities or other property to, from or on behalf of the investment company (other
than ordinary fees for bona fide principal underwriting services). The Adviser has confirmed for the Board that the Closing will not impose
an unfair burden on the Funds within the meaning of Section 15(f) of the 1940 Act.

Second, during the three-year period following the
Closing, at least 75% of the members of the investment company’s board of trustees cannot be “interested persons” (as
defined in the 1940 Act) of the investment adviser (or predecessor adviser). At the present time, 66.7% of the Trustees are classified
as Independent Trustees, i.e., not interested persons of the Trust. The Board has committed to ensuring that at least 75% of the Trustees
would not be “interested persons” of the Adviser for a period of three years after the Closing.

August 5, 2025

Page 6

Eagle Energy Infrastructure Fund

Comment 11: Prior to mailing please ensure that the total number
of outstanding shares are disclosed.

Response: 	The Registrant has included a completed outstanding
shares table. Please see the revised proxy statement attached hereto.

As of the Record Date, there were the number of shares
of beneficial interest of the Fund issued and outstanding as set forth below:

    Voting Securities Outstanding

    Class A
    Class C
    Class I
    Class N

    1,382,424
    773,278
    14,366,274
    4,471,764

Comment 12: Please disclose that the Funds are in compliance with
the two conditions of the safe harbor of Section 15(f) of the Investment Company Act of 1940.

Response: 	The requested revision has been
made. The following disclosure has been added:

Section 15(f) of the 1940 Act

Because the Closing may be considered to result in
a change in control of the Co-Adviser under the 1940 Act resulting in the termination (due to a deemed assignment) of the Former Co-Advisory
Agreement, the Adviser intends for the Closing to come within the safe harbor provided by Section 15(f) of the 1940 Act, which permits
an investment adviser of a registered investment company (or any affiliated persons of the investment adviser) to receive any amount or
benefit in connection with a sale of an interest in the investment adviser that results in an assignment of an investment advisory contract,
provided that the following two conditions are satisfied.

First, an “unfair burden” may not be imposed
on the investment company as a result of the sale of the interest, or any express or implied terms, conditions or understandings applicable
to the sale of the interest. The term “unfair burden,” as defined in the 1940 Act, includes any arrangement during the two-year
period following the transaction whereby the investment adviser (or predecessor or successor adviser), or any “interested person”
of the adviser (as defined in the 1940 Act), receives or is entitled to receive any compensation, directly or indirectly, from the investment
company or its security holders (other than fees for bona fide investment advisory or other services), or from any person in connection
with the purchase or sale of securities or other property to, from or on behalf of the investment company (other than ordinary fees for
bona fide principal underwriting

August 5, 2025

Page 7

services). The Adviser has confirmed for the Board
that the Closing will not impose an unfair burden on the Funds within the meaning of Section 15(f) of the 1940 Act.

Second, during the three-year period following the
Closing, at least 75% of the members of the investment company’s board of trustees cannot be “interested persons” (as
defined in the 1940 Act) of the investment adviser (or predecessor adviser). At the present time, 66.7% of the Trustees are classified
as Independent Trustees, i.e., not interested persons of the Trust. The Board has committed to ensuring that at least 75% of the Trustees
would not be “interested persons” of the Adviser for a period of three years after the Closing.

If you have any questions or additional
comments, please call Andrew Davalla at (216) 566-5706.

Sincerely,

/s/ Andrew Davalla

Andrew Davalla