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INVESTMENT
MANAGERS SERIES TRUST II

235
W. Galena Street

Milwaukee,
Wisconsin 53212

VIA EDGAR

January 18, 2024

U.S. Securities
and Exchange Commission

100 F Street,
NE

Washington, DC 20549

Attention: Division
of Investment Management

 Re: Investment
                                            Managers Series Trust II (the “Registrant”) (File Nos. 333-191476 and 811-22894)
                                            on behalf of the AXS Merger Fund

Ladies
and Gentlemen:

This
letter summarizes the comments provided to me by Ms. Samantha Brutlag of the staff of the Securities and Exchange Commission (the “Commission”)
by telephone on January 11, 2024, regarding Post-Effective Amendment No. 393 to the Registrant’s registration statement filed on
Form N-1A (the “Registration Statement”) on November 29, 2023, relating to the AXS Merger Fund (the “Fund”),
a series of the Registrant.

Responses
to all of the comments are included below and, as appropriate, will be incorporated into a Post-Effective Amendment filing that will
be filed separately. Capitalized terms not otherwise defined in this letter have the meanings assigned to them in the Registration Statement.

SUMMARY
SECTION

Fees
and Expenses

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

Response:
The Fund’s completed fee table and 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. Information
about waivers and discounts is available from your financial professional and in the section titled “YOUR ACCOUNT WITH THE FUNDS
— Purchase of Shares/Class I Shares” on page [123] and in “APPENDIX A — Waivers and Discounts Available from
Intermediaries” on page [153] of the Prospectus.

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    Investor

    Class

    Shares

    Class I

    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

    Redemption
    fee if redeemed within 30 days of purchase (as

    a
    percentage of amount redeemed)

    1.00%

    1.00%

    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

    1.25%

    1.25%

    Distribution
    (Rule 12b-1) fees

    0.25%

    None

    Other
    expenses

    1.08%

    1.08%

    Dividends
    expense on securities sold short
    0.32%

    0.32%

    All
    other expenses
    0.76%

    0.76%

    Acquired
    fund fees and expenses

    0.06%

    0.06%

    Total
    annual fund operating expenses1

    2.64%

    2.39%

    Fee
    waivers and expense reimbursement2

    (0.51)%

    (0.51)%

    Total
    annual fund operating expenses after fee waivers and expense reimbursement1,2

    2.13%

    1.88%

1 The
                                            total annual fund operating expenses and net operating expenses do not correlate to the ratio
                                            of expenses to average net assets appearing in the financial highlights table, which reflects
                                            only the operating expenses of the Fund and does not include acquired fund fees and expenses.

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 1.75% and 1.50% of the average daily net assets of
                                            Investor Class and Class I shares of the Fund, respectively. This agreement is in effect
                                            until January 31, 2025, 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. Such 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. Reimbursements of fees waived or payments made will be made on a “first
                                            in, first out” basis so that the oldest fees waived or payments are satisfied first.

    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.

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

    Investor
    Class Shares
    $216
    $772
    $1,355
    $2,936

    Class
    I Shares
    $191
    $697
    $1,229
    $2,687

Principal
Investment Strategies

 2. The
                                            first sentence of the first paragraph states “[u]nder
                                            normal market conditions, the Fund will invest primarily in equity securities and related
                                            derivatives of U.S. and foreign companies that are involved in publicly announced mergers,
                                            takeovers, tender offers, leveraged buyouts, spin-offs, liquidations and other corporate
                                            reorganizations (collectively, “Merger Transactions”).” The staff believes
                                            that the Fund’s name warrants an 80% investment policy in accordance with Rule 35d-1
                                            under the Investment Company Act of 1940, as amended (the “Names Rule”). Accordingly,
                                            please revert the language in this sentence from “primarily” to “at least
                                            80% of its net assets” to indicate that the Fund has an 80% Names Rule policy.

Response:
The Registrant notes that the Names Rule requires that a fund with a name that suggests that the fund focuses its investments in a particular
type of investment, or in investments in a particular industry or geographic region, adopt a policy to invest, under normal circumstances,
at least 80% of its net assets in the particular type of investment, industry or geographic region suggested by the fund’s name.
However, the Commission stated in the adopting release that the Names Rule does not apply to a fund’s name that connotes a type
of investment strategy. The Registrant believes that under the current Names Rule the term “merger” in the Fund’s name
does not identify a type of investment or industry, but rather indicates that the Fund employs an investment strategy, that, among other
things, seeks to identify companies involved in significant corporate events such as mergers, liquidations or corporate reorganizations.
Accordingly, the Registrant respectfully declines to add an 80% Names Rule policy to the Fund’s investment strategies.

The
Registrant has revised the disclosure as follows:

Under
normal market conditions, the Fund employs a merger strategy by investing primarily in equity securities and related derivatives
of U.S. and foreign companies that are involved in significant corporate events, such as publicly announced mergers, takeovers,
tender offers, leveraged buyouts, spin-offs, liquidations and other corporate reorganizations (collectively, “Merger Transactions”).

The
Registrant is aware of the recently adopted amendments to the Names Rule and the December 10, 2025, compliance date. The Registrant
intends to assess and address the amendments with respect to the Registrant’s series, as necessary, prior to the compliance date.

*
* * * *

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The
Registrant believes that it has fully responded to each comment. If, however, you have any further questions or require further clarification
of any response, please contact me at (626) 385-5777. I may also be reached at diane.drake@mfac-ca.com.

Sincerely,

  /s/
  Diane J. Drake

  Diane J. Drake

  Secretary

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