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July 21, 2023

VIA EDGAR TRANSMISSION

Jaea Hahn, Esq.

Senior Counsel

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0506

Re: Northern Lights Fund Trust III, File Nos. 333-178833 and 811-22655
(“Registrant”)

Dear Ms. Hahn:

On May 30, 2023, the Registrant, on behalf of its
series, Newfound Risk Managed U.S. Growth Fund (to be renamed the “Return Stacked® Risk Managed U.S. Stocks &
Bonds Fund”) filed a registration statement under the Securities Act of 1933 on Form N-1A (the “Amendment”). In a telephone
conversation on July 14, 2023, you provided comments of the Staff of the Securities and Exchange Commission (the “Staff”)
to the Amendment. Below, please find those comments and the Registrant’s responses, which the Registrant has authorized Thompson
Hine LLP to make on its behalf. Please note that added language is in italics and deleted language appears struck through.

In connection with this response, we acknowledge that
the Registrant is responsible for the adequacy and accuracy of the disclosures in its filings; Staff comments or changes to the disclosure
in response to Staff comments do not foreclose the Securities and Exchange Commission from taking any action with respect to the filing:
and the Registrant may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or
any person under the federal securities laws of the United States.

General

Comment 1: Please explain supplementally why
the use of the trademarked term “Return Stacked” would not be misleading to investors under the Rule 35d-1 of the Investment
Company Act of 1940, as amended. The Staff notes that it is uncommon for a trademark to be part of a fund name.

Response: The Registrant respectfully asserts
that “Return Stacked” is not misleading, rather is an accurate description that the Fund’s returns are the result of
the return streams of two distinct strategies which are “stacked” on top of each other. For example, each dollar invested
in the Fund could provide up to two dollars of investment exposure—i.e., each dollar could provide up to one dollar of exposure
to the investments in the Fund’s risk managed U.S. equity strategy and up to

    Philip.Sineneng@ThompsonHine.com     Direct:  614.469.3217

Jaea Hahn, Esq.

July 21, 2023

Page 2

one dollar of exposure to the investments in the Fund’s
risk managed bond strategy. The returns of the bond strategy (net of financing costs) are
stacked on top of the returns of the U.S. equity strategy.

Furthermore, the Registrant notes that the adviser
seeks to align the Fund with the funds under its management that are each a series of Tidal Trust II, namely, Return Stacked Global Stocks
& Bonds ETF and Return Stacked® Bonds & Managed Futures ETF, and the pending Return Stacked U.S. Stocks & Managed
Futures ETF.

Prospectus

Fee Table and Expense Example

Comment 2: Please provide a completed Fee Table
and Expense Example.

Response: The Registrant has amended its disclosures
to state the following:

Shareholder Fees (fees paid directly from your investment)
    Class I

    Maximum Sales Charge (Load) Imposed on purchases (as a percentage of offering price)
    None

    Maximum Deferred Sales Charge (Load)
    None

    Redemption Fee (as a % of amount redeemed if held less than 30 days)
    1.00%

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

    Management Fees
    0.79%

    Distribution and Service (12b-1) Fees
    None

    Total Other Expenses
    0.62%

    	Interest Expense
    	0.02%

    Expense Recapture
    [  ]%

    	Remaining Other Expenses
    	0.60%

    Acquired Fund Fees and Expenses(1)
    0.10%

    Total Annual Fund Operating Expenses
    1.51%

    Fee Waiver and Expense Reimbursement (2)
    (0.14)%

    Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement
    1.37%

 (1) Acquired Fund Fees and Expenses are the indirect
costs of investing in other investment companies, including exchange traded funds. The operating expenses in this fee table will not correlate
to the expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses
incurred by the Fund.

Jaea Hahn, Esq.

July 21, 2023

Page 3

 (2) The Fund’s adviser, Newfound Research LLC
(“the Adviser”), has contractually agreed to waive its fees and reimburse expenses of the Fund, at least until August 1, 2025,
to the extent necessary to ensure that Total Annual Fund Operating Expenses After Fee Waiver and Expense Reimbursement (but does not include:
(i) any front end or contingent deferred loads; (ii) brokerage fees and commissions; (iii) acquired fund fees and expenses; (iv) borrowing
costs (such as interest and dividend expense on securities sold short); (v) taxes; and (vi) extraordinary expenses, such as litigation
expenses (which may include indemnification of Fund officers and Trustees, and contractual indemnification of Fund service providers (other
than the Adviser))) will not exceed 1.25% of average daily net assets
attributable to Class I shares. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund within three
years after the fees have been waived or reimbursed, if such recoupment can be achieved within the foregoing expense limits or within
the expense limits in place at the time of recoupment, whichever is lower, after the recoupment is taken into account. This agreement
may be terminated by the Board of Trustees only on 60 days’ written notice to the Adviser.

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 numbers reflected
herein include the expense caps through the expiration date of the current expense limitation agreement, August 1, 2025, and not thereafter.

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 upon these assumptions your costs would be:

    Class
    1 Year
    3 Years
    5 Years
    10 Years

    I
    $139
    $449
    $796
    $1,777

Comment 3: In footnote 1 to the Fee Table,
the Staff notes that it is customary to see a disclosure that the recoupment is possible only if it possible to stay within the expense
limitations after the recoupment is taken into account. Please consider whether such disclosure is appropriate.

Response: The Registrant refers to its response
to Comment 2.

Principal Investment Strategies

Comment 4: Please clarify whether the Fund
will need to reposition its portfolio to implement its proposed investment strategy. The Staff notes that the proposed Fund name indicates
investments in stocks and bonds whereas the current name only indicates investment in growth securities.

Response: The Registrant confirms that the
adviser does not anticipate any material repositioning of the Fund’s portfolio as a result of the change in the Fund’s name.
The adviser contends that

Jaea Hahn, Esq.

July 21, 2023

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the proposed changes to the Fund’s investment strategy are to align with the proposed name, but do not
represent a material shift from the Fund’s current investment strategy.

Comment 5: Please disclose any material effects
on shareholders as a result of the revised principal investment strategy. For example, will there be any changes to capital gains distributions
as a result of the revised strategy?

Response: The Registrant refers to the response
to Comment 4. The adviser does not anticipate any material effects on shareholders from the change in the Fund’s name and the proposed
changes to the Fund’s investment strategy.

Comment 6: In the first paragraph under
the heading “Principal Investment Strategies,” please define “ETF” and clarify whether the underlying ETFs
will be passive or actively managed, affiliated or unaffiliated with the Advisor, and whether Fund will purchase shares in the
secondary market or intends to purchase creation units directly from the ETFs. Please state whether the Fund invests a certain
percentage of its assets in each category identified in this paragraph.

Response: The Registrant has amended its Item
4 disclosures to state the following:

Principal Investment Strategies: The
Fund is primarily comprised of (i) equity securities of domestic companies of any market capitalization, domestic equity futures contracts
and/or unaffiliated exchange traded funds (“ETFs” and (sometimes referred to in this
Prospectus as “Underlying Funds”) that are actively or passively managed that invest in those companies (“Equity
ETFs”), (ii) 5- and 10-Year U.S. Treasury Note futures contracts, (iii) put and call options on equity indices
and Equity ETFs, (iii) 5- and 10-Year Treasury Note futures contracts and (iv) investment grade short-term fixed income securities
(i.e., short-term U.S. Treasuries) and ETFs that invest in those fixed income securities (“Fixed Income ETFs”).

The Registrant has amended its Item 9
disclosures to state the following:

Principal Investment Strategies:

The Fund is primarily comprised of
(i) equity securities of domestic companies of any market capitalization, domestic equity futures contracts and/or unaffiliated
exchange traded funds (“ETFs”) that are actively or passively managed that invest in those companies (“Equity
ETFs”), (ii) 5- and 10-Year U.S. Treasury Note futures contracts, (iii) put and call options on equity indices
and Equity ETFs, (iii) 5- and 10-Year U.S. Treasury Note futures contracts, and (iv) investment grade short-term fixed income securities
(i.e, short-term U.S. Treasures) and ETFs that invest in

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July 21, 2023

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those fixed income securities (“Fixed Income ETFs”). ETFs are
purchased on the secondary market.

Under normal circumstances, the
Fund will have between 60-90% exposure to equity securities and Equity ETFs, 1-5% exposure to options on equity indices and Equity ETFs,
0-100% notional exposure to 5- and 10 Year U.S. Treasury Note futures contracts and up to 35% exposure to fixed income securities and
Fixed Income ETFs. Notional exposure reflects the value of a trade, not the cost (or market value) of taking the trade.

Comment 7: In romanette (iii) in the same paragraph
referenced in Comment 6, please confirm that for purposes of the 80% test, the Fund will use market value, rather than the notional exposure,
of any options.

Response: The Registrant has given careful
consideration to the Staff’s comment and respectfully disagrees that disclosure relating to the Fund’s 80% test should be
included in the paragraph referred to in Comment 7. The Registrant believes that clarifying the Fund’s 80% test would be less confusing
to shareholders if the disclosure followed the discussion of the 80% test. Therefore, the Registrant has amended its disclosures to state
the following:

The Fund has the flexibility to invest
in any combination of the securities described in the first paragraph above, which include domestic common stock, preferred
stock, depositary receipts, equity swaps, options, equity index futures, and ETFs that invest in these types of securities. Under
normal circumstances, the Fund invests at least 80% of its net assets, plus borrowings for investment purposes, in (a) domestic equity
securities, domestic equity futures contracts and ETFs that, in the aggregate, provide exposure to the U.S. equity markets, and
(b) U.S. Treasuries and/or U.S. Treasury futures contracts that provide the Fund with indirect exposure to the performance of the
U.S. treasury bond market. For purposes of complying with its “80%” policy, the Fund will use the market value of any put
or call options in which it invests. Market value refers to the current price at which an option can be bought or sold on an exchange
or through a broker. The Fund’s “80%” policy is non-fundamental and can be changed without shareholder approval.
The Fund makes direct investments in U.S. Treasuries for capital preservation, capital appreciation and collateral for futures contracts.

Comment 8: The second paragraph under the heading
“Principal Investment Strategies” suggests that the Fund’s strategy is a binary strategy, i.e., either all in
equities or all in fixed income securities. Please confirm if that is true. If not, please explain how much of the portfolio will be allocated
to equities, how much will be allocated to fixed-income securities, and how much will be allocated to U.S. Treasuries under both normal
and stressed conditions. If it is a binary strategy,

Jaea Hahn, Esq.

July 21, 2023

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please disclose whether the strategy will result in frequent portfolio turnover and
add appropriate risk disclosure.

Response: The Registrant refers
to its response to Comment 6. The Registrant notes that the Fund already includes “Turnover Risk” as a principal investment
risk of the Fund.

Comment 9: In the third paragraph under the
heading “Principal Investment Strategies,” is the proprietary model referred to the “return stacked” mentioned
in the Fund’s name? If not, what is the relevance of “return stacked” in the name?

Response: The Registrant has amended its disclosures
to state the following:

The Adviser utilizes rules-based,
quantitative systems to measure market risk and select investments to buy and sell for the Fund. The Adviser adjusts the Fund’s
equity market exposure based upon its proprietary models as necessary. These models may utilize factors including momentum and trend (e.g.,
price return), market structure (e.g., liquidity), volatility, cross-asset signals (e.g., correlation), seasonality, and fundamentals
(e.g., earnings growth) to determine In selecting securities for the Fund’s portfolio, the Adviser focuses on
whether the domestic equity market offers the potential for acceptable risk-adjusted returns (lower volatility and higher price momentum)
that the Adviser deems in its judgment to likely produce positive returns to the Fund. If so, the Fund invests in domestic equities,
and/or Equity ETFs, and/or equity futures.

If not, the Fund invests in investment
grade short-term fixed income securities or Fixed Income ETFs. The Adviser utilizes rules-based, quantitative systems to measure
market risk and select securities to buy and sell for the Fund. The Adviser adjusts the Fund’s equity market exposure based upon
its proprietary models as necessary. These models may utilize factors including, but not limited to, momentum and trend (e.g., price return),
market structure (e.g., liquidity), volatility, cross-asset signals (e.g., correlation), seasonality, and fundamentals (e.g., earnings
growth). The Fund may invest in 5- and 10-Year U.S. Treasury Note futures contracts when the Adviser’s proprietary models
indicate that such a position may offer a positive expected return or meaningful diversification benefits for the portfolio. These models
may utilize factors including, but not limited to, value (e.g., real yield), trend (e.g., price return), carry (e.g., steepness of the
yield curve), and correlation. The Fund is “Return Stacked”® because the returns of the risk managed fixed
income strategy are stacked on top of the returns of the risk managed equity strategy.

Jaea Hahn, Esq.

July 21, 2023

Page 7

Comment 10: In the same paragraph referenced
in Comment 9, please explain the factors that models utilize. What is the basic analysis of the models? What do the proprietary models
do? Please delete the phrase “including, but not limited to” and list the specific factors utilized by the models.

Response: The Registrant refers to its response
to Comm