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INVESTMENT MANAGERS SERIES TRUST

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

October 21, 2024

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Division of Investment Management

 Re: Investment Managers Series Trust (the “Registrant” or “Trust”) (File Nos.
333-122901 and 811-21719) on behalf of the Bahl & Gaynor Income Growth Fund

Ladies and Gentlemen:

This letter summarizes the comments provided to
me by Ms. Soo Im-Tang of the staff of the Securities and Exchange Commission (the “Commission”) by telephone on October 10,
2024, regarding Post-Effective Amendment No. 1234 to the Registrant’s registration statement filed on Form N-1A (the “Registration
Statement”) on August 28, 2024, relating to the Bahl & Gaynor Income Growth Fund (the “Fund”), a series of the Trust.

Responses to all of the comments are included
below and, as appropriate, will be incorporated into a Post-Effective Amendment to the Fund’s 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.

Prospectus

SUMMARY SECTION

Fees and Expenses

 1. The disclosure indicates the Fund may invest in other funds. If the Fund’s Acquired Fund Fees and Expenses (“AFFE”)
exceed 0.01%, please disclose the AFFE, as a separate line item, in the fees and expenses table.

Response: The Registrant confirms
that the Fund’s AFFE do not exceed 0.01%.

 2. Please provide the Fund’s completed fees and expenses table, expense example and performance to the Commission for review at
least five business days prior to the Amendment’s effective date.

Response: The Fund’s completed
fees and expenses tables, expense examples and updated performance are set forth below.

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. More information about these
and other discounts is available from your financial professional and in the sections titled “YOUR ACCOUNT WITH THE FUND –
Purchase of Shares/Class A Shares” on page 17 of the Prospectus and in “APPENDIX A – Waivers and Discounts Available
from Intermediaries” of the Prospectus.

    1

    Shareholder
    Fees

    (fees paid directly from your investment)

    Class
    A

    Shares

    Class
    C

    Shares1

    Class
    I

    Shares

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

    5.50%

    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

    Redemption
    fee if redeemed within 90 days of purchase (as a percentage of amount redeemed)

    2.00%

    2.00%

    2.00%

    Wire
    fee

    $20

    $20

    $20

    Overnight
    check delivery fee

    $25

    $25

    $25

    Retirement
    account fees (annual maintenance fee)

    $15

    $15

    $15

    Annual
    Fund Operating Expenses3

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

    Management
    fees

    0.45%

    0.45%

    0.45%

    Distribution
    and service (Rule 12b-1) fees

    0.25%

    1.00%

    None

    Other
    expenses

    0.15%

    0.15%4

    0.15%

    Shareholder
    service fees
    0.07%

    0.07%

    0.07%

    All
    other expenses
    0.08%

    0.08%

    0.08%

    Total
    annual fund operating expenses

    0.85%

    1.60%

    0.60%

 1. Currently,
                                            Class C Shares are not available for purchase.

 2. For
                                            Class A Shares, no sales charge applies on investments of $1 million or more, but a contingent
                                            deferred sales charge (“CDSC”) of 1.00% will be imposed to the extent a finder’s
                                            fee was paid on certain redemptions of such shares within 18 months of the date of purchase.
                                            Class C Shares of the Fund are subject to a CDSC of 1.00% on any shares sold within 12 months
                                            of the date of purchase.

 3. The
                                            expense information in the table has been restated to reflect the current management fee
                                            and expense caps, effective July 1, 2024.

 4. Other
                                            expenses for Class C Shares are estimated for the current fiscal year, based on current expenses
                                            for the existing share classes.

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.

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

    One Year
    Three Years
    Five Years
    Ten Years

    Class A Shares
    $632
    $806
    $995
    $1,541

    Class C Shares
    $263
    $505
    $871
    $1,900

    Class I Shares
    $61
    $192
    $335
    $750

    2

You would pay the following expenses on Class
C Shares if you did not redeem your shares:

    One Year
    Three Years
    Five Years
    Ten Years

    Class C Shares
    $163
    $505
    $871
    $1,900

Performance

The bar chart and table below provide some indication
of the risks of investing in the Fund by showing changes in the Fund’s performance from year to year for Class I Shares and by showing
how the average annual total returns of each class of the Fund compare with the average annual total returns of a broad-based market index.
Performance for classes other than those shown may vary from the performance shown to the extent the expenses for those classes differ.
Updated performance information is available at the Fund’s website, https://mf.bahl-gaynor.com/or by calling the Fund at 1-833-472-2140.
The Fund’s past performance, before and after taxes, is not necessarily an indication of how the Fund will perform in the future.

Calendar-Year Total Return (before taxes)
for Class I Shares

For each calendar year at net asset value per
share (“NAV”)

The year-to-date return as of September 30, 2024,
was 18.47%.

    Class I Shares

    Highest Calendar Quarter Return at NAV
      14.27%
    Quarter Ended 06/30/2020

    Lowest Calendar Quarter Return at NAV
    (20.54)%
    Quarter Ended 03/31/2020

    3

    Average
    Annual Total Returns

    (for periods ended December 31, 2023)
    1
    Year
    5
    Years
    10
    Years

    Class
    I Shares — Return Before Taxes
    6.79%
    10.32%
    9.15%

    Class
    I Shares — Return After Taxes on Distributions*
    5.86%
    9.58%
    8.52%

    Class
    I Shares — Return After Taxes on Distributions and Sale of Fund Shares*
    4.64%
    8.13%
    7.38%

    Class
    A Shares — Return Before Taxes
    0.73%
    8.82%
    8.26%

    Class
    C Shares — Return Before Taxes**
    4.77%
    9.23%
    8.05%

    S&P
    500 Index (reflects no deduction for fees, expenses or taxes)
    26.29%
    15.69%
    12.03%

 3. Footnote 3 to the Fund’s fees and expenses table states that “Other expenses for Class C shares are estimated for the
current fiscal year, based on current expenses for the existing share classes.” Please consider adding a footnote stating that Class
C Shares are not currently available for purchase.

Response: The Registrant has
added the following footnote:

 1. Currently, Class C Shares are not available for purchase.

Principal Investment Strategies

 4. In the first sentence of the first paragraph, please insert the term “net” before “assets” and add parenthesis
around “plus borrowings”.

Response: The Registrant has
revised the disclosure as follows:

Under normal market conditions, the
Fund invests at least 80% of its net assets (plus borrowings) for investment purposes in equity securities, primarily
common stock, of companies that have historically paid dividends and have strong dividend policies.

 5. The first sentence of the first paragraph states “Under normal market conditions, the Fund invests at least 80% of its assets
plus borrowings for investment purposes in equity securities, primarily common stock, of companies that have historically paid dividends
and have strong dividend policies.” Please disclose what is meant by “strong dividend policies.”

Response: The Registrant has
revised the disclosure as follows:

Under normal market conditions, the
Fund invests at least 80% of its net assets (plus borrowings) for investment purposes in equity securities, primarily common stock, of
companies that have historically paid dividends and have strong dividend policies. The Advisor defines companies with “strong
dividend policies” as companies that demonstrate historic dividend growth in addition to competitive advantages, reasonable valuations,
positive or increasing cash flow returns, and/or sound capital allocation policies or approaches.

 6. The fourth sentence of the first paragraph states “Under normal market conditions, the Fund typically invests in a diversified
portfolio of 35 to 50 securities spread across a variety of economic sectors.” Please specify or provide examples in the disclosure
of the economic sectors the Fund may invest in.

Response: The Registrant has
revised the disclosure as follows:

    4

Under normal market conditions, the
Fund typically invests in a diversified portfolio of 35 to 50 securities spread across a variety of economic sectors, including, for
example, the information technology sector, health care sector, or industrial sector.

 7. The seventh sentence of the first paragraph states “[t]he Fund’s Advisor focuses on high-quality companies that typically
produce steady earnings and dividend growth.” Please disclose what is meant by “high-quality companies”.

Response: The Registrant has
added the following disclosure:

The Fund’s Advisor focuses on
high-quality companies that typically produce steady earnings and dividend growth. The Advisor defines “high quality companies”
as companies that have historically exhibited an ability to grow revenues, earnings, and dividends in a variety of economic environments.

Principal Risks of Investing

 8. The Fund’s Principal Investment Strategies state that the Fund may invest in real estate investment trusts (“REITs”).
Please add risk disclosure concerning investments in REITs under the “Principal Risks of Investing” section.

Response: The Registrant confirms
that the following REIT risk disclosure was already included under the “Principal Risks of Investing” section of the Prospectus.

Real Estate Investment Trust (REIT)
Risk. The Fund’s investment in REITs will subject the Fund to risks similar to those associated with direct ownership of real
estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest
rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses.

 9. The Fund’s “Principal Investment Strategies” state that the Fund may invest in large capitalization companies. Please
add risk disclosure concerning investments in large capitalization companies under the “Principal Risks of Investing” section.

Response: The Registrant has
added the following disclosure:

Large-Cap Company Risk.
Larger, more established companies may be unable to attain the high growth rates of successful, smaller companies during periods of economic
expansion.

 10. The description of “Focused Risk” in the Fund’s “Principal Risks of Investing” section states that “[t]he
Fund’s Advisor intends to focus its investments in the securities of a comparatively small number of issuers.” Please provide
the range of what constitutes a “comparatively small number of issuers”.

Response: The Registrant notes
that the Fund’s “Principal Investment Strategies” state that the Fund typically invests in a diversified portfolio of
35 to 50 securities. Accordingly, the Advisor defines a small number of issuers to be between 35 and 50 issuers. Further, the Registrant
has replaced “comparatively small number of issuers” with “smaller number of issuers”.

    5

More
About The Fund’s Investment Objectives, Principal Investment Strategies and Risks

Principal Investment Strategies

 11. The fourth sentence of the second paragraph states that when selecting the Fund’s investments, “[t]he Advisor performs
a fundamental review looking at quantitative and qualitative comparisons of each company with others in its economic sector.” Please
define or provide examples of the economic sector referenced in this sentence.

Response: The Registrant has
revised the disclosure as follows:

Second, the Advisor performs a fundamental
review looking at quantitative and qualitative comparisons of each company with others in its economic sector (e.g., the information
technology sector, health care sector, or industrial sector).

 12. The fifth sentence of the second paragraph states that when selecting the Fund’s investments, the Advisor uses a “fundamental
security investigation” to “identify high-quality companies with strong dividend growth prospects and at least a 2% current
yield”. Please explain what is a “fundamental security investigation.”

Response: The Registrant has
revised the disclosure as follows:

Third, a bottom-up fundamental
security investigation analysis is used to identify high-quality companies with strong dividend growth prospects
and at least a 2% current yield.

 13. The third paragraph states that one of the reasons the Advisor generally sells a security is when “[t]he Advisor believes the
company’s fundamentals deteriorate….” For clarity, please rephrase the disclosure to confirm if a security is generally
sold by the Advisor if the company’s fundamentals deteriorate since or after the security was purchased.

Response: The Registrant has
revised the disclosure as follows:

2) the Advisor believes the company’s
fundamentals deteriorate after the security was purchased,

 14. The third paragraph states that one of the reasons the Advisor generally sells a security is when it “believes the company’s
stock or income contribution becomes over-weighted in the portfolio due to appreciation or other factors….” Please explain
or rephrase this sentence in plain English.

Response: The Registrant has
revised the disclosure as follows:

3) the Advisor believes the
company’s stock or income contribution becomes over-weighted in the portfolio due to appreciation or other factors the
Advisor rebalances the Fund’s portfolio and determines that the security is over-weighted in the portfolio,

    6

Statement of Additional
Information

Investment Restrictions

 15. Please note the Staff’s policy with respect to the Fund’s concentration policy - the Fund may not ignore the concentration
policy of the underlying funds in which the Fund invests in. Please add disclose stating that, with respect to the investment restriction
regarding concentration, the Fund will consider the concentration policy of the Underlying Funds in which it invests.

Response: The Registrant has
added the following disclosure:

In applying the