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INVESTMENT MANAGERS SERIES TRUST

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

March 27, 2020

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 WCM China Quality Growth Fund, WCM Focused ESG International Fund and WCM Focused
ESG Emerging Markets Fund (each a “Fund” and collectively, the “Funds”)

Ladies and Gentlemen:

This letter summarizes the comments provided
to me by Mr. Jonathan Grvesksewicz of the staff of the Securities and Exchange Commission (the “Commission”) by telephone
on March 2, 2020, regarding Post-Effective Amendment No. 1070 the Registrant’s Form N-1A registration statement filed on
January 16, 2020, with respect to the WCM China Quality Growth Fund, WCM Focused ESG International Fund and WCM Focused ESG Emerging
Markets Fund, each a series of the Registrant. Responses to all of the comments are included below and, as appropriate, will be
reflected in a Post-Effective Amendment to the Funds’ Form N-1A registration statement (the “Amendment”), which
will be filed separately.

PROSPECTUS

SUMMARY SECTION

Fees and Expenses Table – All Funds

 1. Please provide the completed fee table and expense example for each Fund in correspondence to the
Commission one week in advance of the registration statement becoming effective.

Response:
Each Fund’s completed fee table and expense example, which will be included in the Amendment, are as follows:

    1

WCM China Quality Growth Fund

Fees and Expenses of the Fund

This table describes the fees and expenses
that you may pay if you buy and hold shares of the Fund.

        Investor

        Class Shares

    Institutional Class Shares

    Shareholder Fees

(fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases

    None

    None

    Maximum deferred sales charge (load)

    None

    None

    Wire fee

    $20

    $20

    Overnight check delivery fee

    $25

    $25

    Retirement account fees (annual maintenance fee)

    $15

    $15

    Annual Fund Operating Expenses

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

    Management fees

    1.00%

    1.00%

    Distribution (Rule 12b-1) fee

    0.25%

    None

    Other expenses1

    0.64%

    0.64%

    Shareholder service fee
    0.15%

    0.15%

    All other expenses
    0.49%

    0.49%

    Total annual fund operating expenses

    1.89%

    1.64%

    Fees waived and/or expenses reimbursed2

    (0.39%)

    (0.39%)

    Total annual fund operating expenses after waiving fees and/or reimbursing expenses1,2

    1.50%

    1.25%

 1 “Other expenses” have been estimated for the current fiscal year. Actual expenses may
differ from estimates.

 2 The Fund’s advisor 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 any taxes, leverage interest, brokerage commissions,
dividend and interest expenses on short sales, acquired fund fees and expenses (as determined in accordance with SEC Form N-1A),
expenses incurred in connection with any merger or reorganization, and extraordinary expenses such as litigation expenses) do not
exceed 1.50% and 1.25% of the average daily net assets of the Fund’s Investor Class and Institutional Class shares, respectively.
This agreement is in effect until August 31, 2021, and it may be terminated before that date only by the Trust’s Board of
Trustees. The Fund’s advisor is permitted to seek reimbursement from the Fund, subject to certain limitations, of fees waived
or payments made to the Fund for a period ending three full 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.

    2

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:

    One Year
    Three Years

    Investor Class
    $153
    $556

    Institutional Class
    $127
    $479

WCM Focused ESG International Fund

Fees and Expenses of the Fund

This table describes the fees and expenses
that you may pay if you buy and hold shares of the Fund.

        Investor

        Class Shares

    Institutional Class Shares

    Shareholder Fees

(fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases

    None

    None

    Maximum deferred sales charge (load)

    None

    None

    Wire fee

    $20

    $20

    Overnight check delivery fee

    $25

    $25

    Retirement account fees (annual maintenance fee)

    $15

    $15

    Annual Fund Operating Expenses

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

    Management fees

    0.85%

    0.85%

    Distribution (Rule 12b-1) fee

    0.25%

    None

    Other expenses1

    0.64%

    0.64%

    Shareholder service fee
    0.15%

    0.15%

    All other expenses
    0.49%

    0.49%

    Total annual fund operating expenses

    1.74%

    1.49%

    Fees waived and/or expenses reimbursed2

    (0.24%)

    (0.24%)

    Total annual fund operating expenses after waiving fees and/or reimbursing expenses1,2

    1.50%

    1.25%

 1 “Other expenses” have been estimated for the current fiscal year. Actual expenses may
differ from estimates.

 2 The Fund’s advisor 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 any taxes, leverage interest, brokerage commissions,
dividend and interest expenses on short sales, acquired fund fees and expenses (as determined in accordance with SEC Form N-1A),
expenses incurred in connection with any merger or reorganization, and extraordinary expenses such as litigation expenses) do not
exceed 1.50% and 1.25% of the average daily net assets of the Fund’s Investor Class and Institutional Class shares, respectively.
This agreement is in effect until August 31, 2021, and may be terminated before that date only by the Trust’s Board of Trustees.
The Fund’s advisor is permitted to seek reimbursement from the Fund, subject to certain limitations, of fees waived or payments
made to the Fund for a period ending three full 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.

    3

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:

    One Year
    Three Years

    Investor Class
    $153
    $525

    Institutional Class
    $127
    $447

    4

WCM Focused ESG Emerging Markets Fund

Fees and Expenses of the Fund

This table describes the fees and expenses
that you may pay if you buy and hold shares of the Fund.

        Investor

        Class Shares

    Institutional Class Shares

    Shareholder Fees

(fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases

    None

    None

    Maximum deferred sales charge (load)

    None

    None

    Wire fee

    $20

    $20

    Overnight check delivery fee

    $25

    $25

    Retirement account fees (annual maintenance fee)

    $15

    $15

    Annual Fund Operating Expenses

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

    Management fees

    1.00%

    1.00%

    Distribution (Rule 12b-1) fee

    0.25%

    None

    Other expenses1

    0.64%

    0.64%

    Shareholder service fee
    0.15%

    0.15%

    All other expenses
    0.49%

    0.49%

    Total annual fund operating expenses

    1.89%

    1.64%

    Fees waived and/or expenses reimbursed2

    (0.39%)

    (0.39%)

    Total annual fund operating expenses after waiving fees and/or reimbursing expenses1,2

    1.50%

    1.25%

 1 “Other expenses” have been estimated for the current fiscal year. Actual expenses may
differ from estimates.

 2 The Fund’s advisor 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 any taxes, leverage interest, brokerage commissions,
dividend and interest expenses on short sales, acquired fund fees and expenses (as determined in accordance with SEC Form N-1A),
expenses incurred in connection with any merger or reorganization, and extraordinary expenses such as litigation expenses) do not
exceed 1.50% and 1.25% of the average daily net assets of the Fund’s Investor Class and Institutional Class shares, respectively.
This agreement is in effect until August 31, 2021, and may be terminated before that date only by the Trust’s Board of Trustees.
The Fund’s advisor is permitted to seek reimbursement from the Fund, subject to certain limitations, of fees waived or payments
made to the Fund for a period ending three full 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.

    5

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:

    One Year
    Three Years

    Investor Class
    $153
    $556

    Institutional Class
    $127
    $479

Principal Investment Strategies –
WCM China Quality Growth Fund

 2. The second sentence of the first paragraph states, “[t]he Fund’s advisor considers
a company to be a Chinese company if it has been organized under the laws of, has its principal offices in, or has its securities
principally traded in, China, or if the company derives at least 50% of its revenues, net profits or incremental revenue growth
(typically over the past five years) from, or has at least 50% of assets or production capacities in China.” Please explain
what is meant by “incremental revenue growth” and why that is an acceptable measure in considering whether a company
is a Chinese company. In addition, please provide an example of how “incremental revenue growth” works.

Response:
In this context, if a company derives 50% (or more) of its incremental revenue growth from China, it means that half or more of
all new revenue for a given reporting period stems from sales made to customers in China. Companies possessing this characteristic
tend to increasingly depend on, and integrate with the Chinese market place. These names may ultimately possess significant enough
China exposure necessary for portfolio inclusion. Typically, this criteria would not be used on a stand-alone basis, but rather
used in conjunction with the other criteria detailed in the first paragraph under the Fund’s Principal Investment Strategies

 3. The Commission notes that it appears “incremental revenue growth” was added to the
principal investment strategies section of the WCM Focused International Growth Fund’s prospectus in the Registrant’s
Post-Effective Amendment No. 786 (“PEA No. 786”) filed on August 26, 2016. Please explain why this was an immaterial
change.

Response:
The “incremental revenue growth” disclosure that was added to the principal investment strategies section of the WCM
Focused International Growth Fund’s prospectus in PEA No. 786 is the same disclosure that is included in the WCM Focused
Emerging Markets Fund’s principal investment strategies, and has been since April 2013. The Registrant confirms that the
addition of this disclosure to the WCM Focused International Growth Fund’s principal investment strategies was for clarification
and consistency purposes, and did not represent a material change to the WCM Focused International Growth Fund’s principal
investment strategies.

Principal Risks of Investing – WCM China
Quality Growth Fund

 4. Please consider adding disclosure regarding the impact of infectious illnesses and other public
health threats to the “Risks Associated with China, Hong Kong and Taiwan” risk factor.

    6

Response:
The Registrant has added the dislosure, noted below in underlined text, to the “Market Risk” and “Risks Associated
with China, Hong Kong and Taiwan” risk factors in the prospectus, and to the “Developments in the China Region”
and “Market Conditions” sections in the statement of additional information:

Market Risk. The market price
of a security or instrument may decline, sometimes rapidly or unpredictably, due to general market conditions that are not specifically
related to a particular company, such as real or perceived adverse economic or political conditions throughout the world, changes
in the general outlook for corporate earnings, changes in interest or currency rates, or adverse investor sentiment generally.
In addition, local, regional or global events such as war, acts of terrorism, the spread of infectious illness or other public
health issues, or other events could have a significant impact on a security or instrument. The market value of a security
or instrument also may decline because of factors that affect a particular industry or industries, such as labor shortages or increased
production costs and competitive conditions within an industry.

Risks Associated with China,
Hong Kong and Taiwan.

China: The Chinese government exercises
significant control over China’s economy through its industrial policies (e.g., allocation of resources and other preferential
treatment), monetary policy, management of currency exchange rates, and management of the payment of foreign currency denominated
obligations. Changes in th