SecProbe.io

CORRESP
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September 13, 2024

VIA EDGAR TRANSMISSION

Seamus O’Brien, 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 Mr. O’Brien:

On July 9, 2024, the Registrant, on behalf of its
proposed series, ABS Insights Emerging Markets Fund, filed a registration statement under the Securities Act of 1933 on Form N-1A (the
“Amendment”). In a telephone conversation on August 23, 2024, 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: Where a comment is made with regard
to disclosure in one location of the Registration Statement, it is applicable to similar disclosure appearing elsewhere in the Registration
Statement. Furthermore, we note that portions of the Registration Statement are incomplete. Please complete all bracketed language and
refresh the Table of Content prior to effectiveness.

Response: The Registrant has completed all
missing information, confirmed all bracketed language, updated the Table of Contents, and updated all disclosures throughout the Registration
Statement as applicable.

    Philip.Sineneng@ThompsonHine.com     Direct:  614.469.3217

    Seamus O’Brien, Esq.

September 13, 2024

Page 2

Prospectus

Fee Table and Expense Example

Comment 2: Please provide a completed Fee Table
and Expense Example. Please update the footnote regarding fee waivers and expense reimbursements and confirm that the fee waiver agreement
will be in place for at least one year from the effectiveness of the Prospectus.

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

Shareholder Fees

(fees paid directly from your investment)

    Institutional

    Class

    Super Institutional

    Class

    Maximum Sales Charge (Load) Imposed on Purchases

(as a % of offering price)
    None
    None

    Maximum Deferred Sales Charge (Load)
    None
    None

    Redemption Fee

(as a % of amount redeemed if held less than 30 days)
    None
    None

    Annual Fund Operating Expenses

(expenses that you pay each year as a

percentage of the value of your investment)

    Management Fees
    0.95%
    0.95%

    Distribution and Service (12b-1) Fees
    None
    None

    Other Expenses (1)
    0.42%
    0.28%

    Acquired Fund Fees and Expenses (1)(2)
    0.01%
    0.01%

    Total Annual Fund Operating Expenses
    1.38%
    1.24%

    Fee Waiver/Expense Reimbursement (23)
    (0.28)%
    (0.28)%

    Total Annual Fund Operating Expenses After Fee Waiver
    1.10%
    0.96%

 (1) Estimated for the current fiscal period.

 (2) Acquired Fund Fees and Expenses are the indirect costs of investing in
other investment companies, including exchange-traded funds (“ETFs”). 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.

 (3) The Fund’s advisor has contractually agreed to waive its fees and
reimburse expenses of the Fund, at least until January 26, 2026 2025 to ensure that Total Annual Fund Operating
Expenses After Fee Waiver and Reimbursement (excluding (i) any front-end or contingent deferred loads; (ii) brokerage fees and commissions;
(iii) acquired fund fees and expenses; (iii) borrowing costs (such as interest and dividend expense on securities sold short); (iv) taxes;
and (v) extraordinary expenses, such as litigation expenses (which may include indemnification of Fund officers and Trustees, contractual
indemnification of Fund service providers (other than the Fund’s advisor))) do not exceed 1.09%% and 0.95% of average
daily net assets attributable to Institutional Class and Super Institutional Class shares, respectively. These fee waivers and expense
reimbursements are subject to possible recoupment from the Fund within the three years after the fees are waived or reimbursed, if such
recoupment can be achieved within the lesser of the foregoing limits or limits in place at time of recoupment 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 Fund’s advisor.

    Seamus O’Brien, Esq.

September 13, 2024

Page 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. Although your actual costs may be higher
or lower, based upon these assumptions your costs would be:

    Class
    1 Year
    3 Years

    Institutional
    $112
    $409

    Super Institutional
    $198
    $366

Comment 3: Please confirm whether the Fund
will have any acquired fund fees and expenses. If so, please confirm whether acquired fund fees and expenses are included with “Other
Expenses.”

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

Principal Investment Strategies

Comment 4: Please provide clarifying/explanatory
disclosure for “governmental or quasi-governmental entities of an emerging market” in an appropriate section of the Registration
Statement.

Response: The Registrant has amended its Item
9 disclosures on page 6 of the Prospectus to state the following:

Securities considered to be economically
tied to emerging market countries include, without limitation: . . . (4) a governmental entity (such as federal or local governments)
or quasi-governmental entity (such as a transportation or healthcare agency that provides specific governmental services but without
any governing authority) of an emerging market; . . .

Comment 5: Please reconcile the disclosure
in the third paragraph of the section under the heading “Principal Investment Strategies” defining “equity-related instruments”
for purposes of the Fund’s 80% policy with the disclosure in the first paragraph of the same section that the Fund invests at least
80% of its net assets “in equity securities of emerging markets companies.”

    Seamus O’Brien, Esq.

September 13, 2024

Page 4

Response: The Registrant has amended the disclosure
of the Fund’s 80% policy to state as follows:

The Fund invests at least 80% of its
net assets, plus any borrowings for investment purposes, in equity-related instruments securities of emerging
markets companies.

Comment 6: In the last sentence of the last
paragraph of the section under the heading “Principal Investment Strategies,” please clarify how the Index can be used as
a guideline for country, sector, market cap, style and position size diversification.

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

The Advisor manages multiple portfolios
focused on emerging markets. To achieve the Fund’s investment objective, the Advisor employs a systematic process that ranks the
stocks of these portfolios in order of the most heavily traded stock positions by country relative to the MSCI Emerging Markets Index
(the “Index”). Securities are selected for the Fund based on these relative rankings. The Advisor aims for the Fund’s
uses the Index as a guideline for country, sector, market cap, style, and position size diversification to reflect
that of the Index.

Advisor’s Prior Related Performance Information

Comment 7: The following comments relate to
the disclosure of the advisor’s prior related performance:

 (a) For open end funds, prior performance information may not be included in
the summary prospectus or in the risk return summary of the prospectus. Only information required or permitted by Items 2 through 8 of
Form N-1A may be included in either the summary prospectus or the risk return summary of the prospectus.

 (b) In the first sentence of the disclosure, please disclose that the Related
Fund has substantially similar investment objectives, policies and investment strategies rather than stating that the related fund “us[es]
the same strategies as the Fund.”

 (c) Please add disclosure that the performance information includes all accounts
that are substantially similar to the Fund managed by the advisor.

 (d) The disclosure indicates that the performance information is “shown
gross and net of management fees and other operating expenses,” but only one set of data is provided. Please make sure that net
numbers have greater prominence than gross numbers.

    Seamus O’Brien, Esq.

September 13, 2024

Page 5

 (e) The disclosure indicates that the performance is shown “for separate
accounts” but does not include data for any separately managed accounts. Please reconcile.

 (f) Please confirm that the advisor has the records necessary to support the
calculation of the Related Fund’s performance as required Rule 204-2(a)(16) of the Investment Advisors Act of 1940, as amended.

 (g) Prior performance must present the average annual total returns for the
1-year, 5-year and 10-years of operations (or since inception if less than 10 years). Performance may include additional years (i.e.,
3-year) so long as the 1-year, 5-year and 10-yeare figures are presented.

Response: The Registrant has moved its discussion
of the Advisor’s Prior Related Performance Information to its Item 9 disclosures immediately after its disclosure of Principal Investment
Risks and confirms that the advisor has maintained all the records necessary to support the calculation of the Related Funds’ performance.
The Registrant has amended its disclosures to state the following:

Advisor’s Prior Related Performance
Information: The Advisor is responsible for managing a two related funds using substantially
the same investment objective, policies and investment strategies as the Fund (the “Related Funds”). The
Advisor has full discretionary authority over the selection of investments for the Related Funds and intends to use substantially
the same goals and style of investment management in managing the Fund. The Related Funds are the only accounts managed by the Advisor
with The Fund has substantially the same investment objective, policies and strategies as the Related Fund.

The information for the Related Funds
is provided to show the past performance as measured against the specified benchmark index and is shown gross and net of management fees
and other operating expenses, including any sales loads, for separate accounts and gross and net of management fees and other
operating expenses, including any sales loads, for private funds. The Related Funds had lower total expenses that the
Fund. Accordingly, the performance shown below would have been lower if such Related Funds had the Fund’s expense structure.
The performance of the Related Funds does not represent the historical performance of the Fund and should not
be considered indicative of future performance of the Fund. In addition, the Related Funds are is not subject
to certain investment limitations and other restrictions imposed by the 1940 Act and the Internal Revenue Code which, if applicable, might
have adversely affected the performance of the Related Funds during the periods shown.

    Seamus O’Brien, Esq.

September 13, 2024

Page 6

Average Annual Total Returns

(as of August 30, 2024)

    1-Year
    5-Year

    Since

    4/1/181

    Related Fund 1 (Net of fees)
    10.27%
    6.66%
    2.82%

    Related Fund 1 (Gross of fees)
    10.98%
    7.35%
    3.49%

    MSCI Emerging Markets Index3
    15.07%
    4.79%
    1.58%

    1-Year

    Since

    7/19/232

    Related Fund 2 (Net of fees)
    11.31%
    7.08%

    Related Fund 1 (Gross of fees)
    12.19%
    7.93%

    MSCI Emerging Markets Index3
    15.07%
    9.29%

Average Annual Total Returns

For Calendar Year/Period Ended
December 31

    2023
    2022
    2021
    2020
    2019
    20181

    Related Fund 1

    (Net of fees)

    11.53%
    (22.00)%
    7.05%
    23.26%
    16.68%
    (16.45)%

    Related Fund 1

    (Gross of fees)

    12.25%
    (21.47)%
    7.74%
    24.04%
    17.42%
    (16.04)%

    MSCI Emerging Markets Index3
    9.83%
    (20.09)%
    (2.54)%
    18.30%
    18.42%
    (15.76)%

    20232

    Related Fund 1

    (Net of fees)

    1.40%

    Related Fund 1

    (Gross of fees)

    1.81%

    MSCI Emerging Markets Index3
    1.25%

    Seamus O’Brien, Esq.

September 13, 2024

Page 7

1 Related Fund 1 commenced
operations on April 1, 2018.

2 Related Fund 2 commenced
operations on July 19, 2023.

3 The MSCI Emerging
Markets Index captures large and mid-cap representation across 24 emerging markets countries. With 1,330 constituents, the index covers
approximately 85% of the free float-adjusted market capitalization in each country. Emerging market countries include Brazil, Chile, China,
Colombia, Czech Republic, Egypt, Greece, Hungary, India, Indonesia, Korea, Kuwait, Malaysia, Mexico, Peru, Philippines, Poland, Qatar,
Saudi Arabia, South Africa, Taiwan, Thailand, Turkey and United Arab Emirates.

If you have any questions, please call JoAnn M. Strasser
at (614) 469-3265 or the undersigned at (614) 469-3217.

Very truly yours,

/s/ Philip B. Sineneng

Philip B. Sineneng

 cc: JoAnn M. Strasser