SecProbe.io

CORRESP
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INVESTMENT
MANAGERS SERIES TRUST

235
W. Galena Street

Milwaukee,
Wisconsin 53212

VIA
EDGAR

March
22, 2024

Securities
and Exchange Commission

100
F Street, NE

Washington, DC 20549

Attention:
Division of Investment Management

 Re: Investment
                                            Managers Series Trust (the “Trust” or “Registrant”) (File Nos. 333-122901
                                            and 811-21719) on behalf of the Gramercy Emerging Markets Debt Fund

Ladies
and Gentlemen:

This
letter includes a corrected fees and expenses table and expense example with respect to the Gramercy Emerging Markets Debt Fund (the
“Fund”), a series of the Trust. The fees and expenses table and expense example below replaces the version included in the
response letter filed on March 21, 2024, which summarized the comments provided to me by Mr. David Orlic of the staff of the Securities
and Exchange Commission (the “Commission”) by telephone on March 5, 2024, regarding Post-Effective Amendment No. 1220 to
the Registrant’s Form N-1A registration statement (the “Registration Statement”) filed on January 17, 2024, with respect
to the Fund. The corrected fees and expenses table and expense example will be reflected in a Post-Effective Amendment to the Fund’s
Registration Statement (the “Amendment”) that will be filed separately.

PROSPECTUS

SUMMARY
SECTION

Fees
and Expenses Table

 1. Please
                                            provide the Fund’s completed fees and expenses table and expense example to the Commission
                                            for review at least five business days prior to filing the Amendment.

Response:
The Fund’s completed fees and expenses table and expense example are as follows:

Fees
and Expenses of the Fund

This
table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such
as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and example below. You
may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in Class A Shares
of the Fund in a single transaction. More information about these fees and other discounts is available from your financial professional
and in the section titled “Choosing a Share Class” on page 29 of the Prospectus and in “APPENDIX A – Waivers
and Discounts Available from Intermediaries and Conversion Policies” of the Prospectus.

    1

    Class
    A

    Shares

    Class
    C

    Shares

    Institutional

    Class

    Shares

    Shareholder
                                            Fees

    (fees
    paid directly from your investment)

    Maximum
    sales charge (load) imposed on purchases (as a percentage of offering price)

    4.25%(1)

    None

    None

    Maximum
    deferred sales charge (load) (as a percentage of the lesser of the value redeemed or the amount invested)

    1.00%(2)

    1.00%(2)

    None

    Wire
    fee

    $20

    $20

    $20

    Overnight
    check delivery fee

    $25

    $25

    $25

    Retirement
    account fees (annual maintenance fee)

    $15

    $15

    $15

    Annual
                                            Fund Operating Expenses

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

    Management
    fees

    0.75%

    0.75%

    0.75%

    Distribution
    and service (Rule 12b-1) fees

    0.25%

    1.00%

    None

    Other
    expenses (3)

    0.51%

    0.51%

    0.51%

    Shareholder
    service fee
    0.08%

    0.08%

    0.08%

    All
    other expenses
    0.43%

    0.43%

    0.43%

    Total
    annual fund operating expenses

    1.51%

    2.26%

    1.26%

    Fees
    waived and/or expenses reimbursed (4)

    (0.41%)

    (0.41%)

    (0.41%)

    Total
    annual fund operating expenses after waiving fees and/or reimbursing expenses (4)

    1.10%

    1.85%

    0.85%

 1 No
                                            initial sales charge is applied to purchases of $1 million or more.

 2 A
                                            contingent deferred sales charge (“CDSC”) of 1.00% will be charged on certain
                                            Class A Share purchases of $1 million or more that are redeemed in whole or in part within
                                            12 months of the date of purchase. A CDSC of 1.00% will be charged on Class C Share purchases
                                            that are redeemed in whole or in part within 12 months of the date of purchase.

 3 Other
                                            expenses for Class A, Class C and Institutional Class shares are estimated for the current
                                            fiscal year, based on current expenses for the existing share classes.

 4 The
                                            Fund’s adviser has contractually agreed to waive its fees and/or pay for operating
                                            expenses of the Fund to ensure that total annual fund operating expenses (excluding, as applicable,
                                            taxes, leverage interest, brokerage commissions, dividend and interest expenses on short
                                            sales, acquired fund fees and expenses (as determined in accordance with Form N-1A), professional
                                            fees related to services for the collection of foreign tax reclaims, expenses incurred in
                                            connection with any merger or reorganization and extraordinary expenses such as litigation
                                            expenses) do not exceed 1.10%, 1.85% and 0.85% of the average daily net assets of the Class
                                            A Shares, Class C Shares and Institutional Shares, respectively. Class C Shares are not available
                                            for purchase. This agreement is in effect through April 30, 2025, and may be terminated before
                                            that date only by the Trust’s Board of Trustees. The Fund’s adviser is permitted
                                            to seek reimbursement from the Fund for a period ending three full fiscal years after the
                                            date of the waiver or payment. This reimbursement may be requested from the Fund if the reimbursement
                                            will not cause the Fund’s annual expense ratio to exceed the lesser of (a) the expense
                                            limitation in effect at the time such fees were waived or payments made, or (b) the expense
                                            limitation in effect at the time of the reimbursement.

Example

This
example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds.

The
example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those
periods. The example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain
the same. The example reflects the Fund’s contractual fee waiver and/or expense reimbursement only for the term of the contractual
fee waiver and/or expense reimbursement.

Although
your actual costs may be higher or lower, based on these assumptions your costs would be:

    2

    One
    Year
    Three
    Years

    Class
    A Shares
    $532
    $843

    Class
    C Shares
    $291
    $667

    Institutional
    Class Shares
    $87
    $359

You
would pay the following expenses if you did not redeem your shares:

    One
    Year
    Three
    Years

    Class
    C Shares
    $188
    $667

If
you have any questions or require further clarification, please contact me at (626) 385-5777 or diane.drake@mfac-ca.com.

    Sincerely,

    /s/
    Diane J. Drake

    Diane
    J. Drake

    Secretary

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