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INVESTMENT
MANAGERS SERIES TRUST II

235
W. Galena Street

Milwaukee, Wisconsin 53212

VIA
EDGAR

July
8, 2024

Ms.
Soo Im-Tang

Division
of Investment Management

U.S.
Securities and Exchange Commission 100 F Street, NE

Washington,
DC 20549

Re: Investment Managers Series Trust
     II (the “Registrant”) on behalf of the Tradr 2X Long Innovation ETF, Tradr 2X Short TSLA Daily ETF, Tradr 1.5X Short
     NVDA Daily ETF, Tradr 2X Short Innovation Daily ETF

Dear
Ms. Im-Tang:

This
letter summarizes the comments you provided on behalf of the staff (the “Staff”) of the Securities and Exchange Commission
(the “SEC”) via telephone on June 14, 2024, regarding Post-Effective Amendment No. 409 to the Registrant’s registration
statement filed on Form N-1A (the “Registration Statement”) on May 15, 2024, relating to the Tradr 2X Long Innovation ETF
(the “Long Innovation ETF”), Tradr 2X Short TSLA Daily ETF (the “TSLA Daily ETF”), Tradr 1.5X Short NVDA Daily
ETF (the “NVDA Daily ETF”), and Tradr 2X Short Innovation Daily ETF (the “Short Innovation ETF”), each 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 filing that will
be filed separately. Capitalized terms not otherwise defined in this letter have the meanings assigned to them in the Registration Statement.

GENERAL

 1. Please provide
                                            the fee table and expense example for each Fund at least 5 days prior to effectiveness.

Response:
The completed fee tables and expense examples for each Fund is shown in the attached Appendix A.

 2. Please
                                            confirm whether any of the Funds will have an “Acquired Fund Fees and Expense”
                                            line item in their Fees and Expenses table.

Response:
The Registrant confirms that none of the Funds have an “Acquired Fund Fees and Expenses” line item in their respective Fees
and Expenses Table.

 3. The
                                            TSLA Daily ETF, NVDA Daily ETF, and the Short Innovation ETF have increased their leverage
                                            thereby significantly increasing each Fund’s risk profile. Please inform the Staff
                                            why the Funds’ board of trustees (the “Board”) believes these are consistent
                                            with its fiduciary duties and in the best interests of shareholders. In your response please
                                            explain: (a) what information the Board considered and how it weighted it in arriving at
                                            its decision; (b) why the Board concluded that this approach was better for shareholders
                                            rather than other options such as liquidating the existing Fund and/or starting a new Fund;
                                            and (c) if this change in strategy will be clearly disclosed to the investor.

Response:
The Registrant notes that, at a meeting held on May 6,
2024, the Board considered the proposed changes to the investment objectives and principal investment strategies of the TSLA Daily ETF,
NVDA Daily ETF, and the Short Innovation ETF, the approval of which would result in increased leverage for each of the Funds. Representatives
from the Funds’ investment advisor, AXS Investments, LLC (the “Advisor”), spoke at the meeting and requested the Board’s
approval to revise the Funds’ strategies so as to increase leverage in response to competition in the marketplace and investor
demand for increased leverage with respect to the applicable underlying securities. In particular, the Advisor representatives noted
that the vast majority of leveraged short ETFs currently offered in the market, especially single-stock based ETFs, offer at least -2X
returns relative to their underlying securities. In addition, the Advisor noted that competitors were now offering 2X inverse leveraged
ETFs tied specifically to TSLA and NVDA. The Board considered the Advisor’s view that the Funds’ increase in inverse leverage
would allow current shareholders to express their hedging or negative viewpoint of the underlying issuers with less capital outlay, lessen
the need for margin borrowing, and attract new shareholders who thought the original leverage was too low.

The
Board also considered the Advisor’s ability to manage products with increased leverage as well as the Advisor’s plans to
modify the derivatives risk management program for the Funds and monitor the Funds’ increased leverage risks. In addition, the
Board noted that the initial registration statement for both TSLA Daily ETF and NVDA Daily ETF contemplated 2X inverse leverage.

The
Board also noted alternative options available to the Funds such as liquidation and/or launching additional leveraged and inverse leveraged
ETFs with varying exposures to the underlying securities. As noted above, the Board considered the market demand for these products and
determined that Fund shareholders would be best served by a single ETF offering with the proposed increase in leverage, rather than multiple
ETF options with varying leverage levels. Accordingly, the Board noted that disclosure of the planned changes to the Funds’ objectives,
strategies, and leverage would be made, and shareholders would have the opportunity to sell their Shares in the event they do not want
additional leveraged exposure to the underlying securities.

To
that end, the Registrant notes that investors of each of the TSLA Daily ETF, NVDA Daily ETF, and the Short Innovation ETF have been notified
of the planned changes to the Funds’ names, investment objectives and principal investment strategies via press release and a 497
supplement filed with the SEC via EDGAR on May 15, 2024. The Registrant has also created a new website for these ETFs with a banner alerting
investors to the new leverage: https://www.tradretfs.com/. Further, the Registrant notes that the front cover page of the Funds’
prospectus will reflect that each of the Funds’ names have changed, and the updated prospectus will disclose each of the Funds’
updated investment objectives and principal investment strategies, including a description of the Funds’ increased leverage.

 4. On the second
                                            page of the prospectus where it states “[t]he ETFs are not suitable for all investors,”
                                            please change it to state “[T]hese Funds” or “[T]hese ETFs.”

Response:
The Registrant has revised the sentence as follows:

“These Funds are not suitable for all investors.”

 5. On
                                            the third page of the prospectus it states “[w]ith respect to the TSLA Daily ETF and
                                            NVDA Daily ETF, AXS Investments, LLC, the Funds’ investment advisor, will not attempt
                                            to position each Fund’s portfolio to ensure that a Fund does not gain or lose more
                                            than a maximum percentage of its net asset value on a given trading day.” Please apply
                                            this sentence to the Long Innovation ETF and Short Innovation ETF, if applicable.

Response:
The Registrant has revised the sentence as follows:

“AXS
Investments, LLC, the Funds’ investment advisor (the “Advisor”), will not attempt to position each Fund’s
portfolio to ensure that a Fund does not gain or lose more than a maximum percentage of its net asset value on a given trading day.”

 6. With
                                            respect to the TSLA Daily ETF, NVDA Daily ETF, and the Short Innovation ETF, please advise,
                                            providing hypothetical calculations, how each of these Funds anticipates being able to achieve
                                            its objective while remaining in compliance with the Rule 18f-4 value-at-risk (“VaR”)
                                            test. In responding to this comment, please disclose the designated reference portfolio (index)
                                            that each Fund plans to use and discuss how the index meets the definition of designated
                                            reference portfolio and is in accordance with Rule 18f-4.

Response:
The Funds’ portfolio transactions are conducted pursuant to a written derivatives risk management program, which includes policies
and procedures that are reasonably designed to manage the risks of the Funds’ usage of derivatives, as required by Rule 18f-4.
The program is administered and overseen by a committee that has been designated by the Board as the derivatives risk manager. The program
identifies and provides an assessment of the Funds’ derivatives usage and risks as they pertain to the Funds’ usage of swaps
and any other derivatives as applicable. The program includes risk guidelines that, among other things, consider and provide for: (1)
limits on the Funds’ derivatives exposure; (2) monitoring and assessment of the Funds’ exposure to illiquid investments (if
any); (3) monitoring and assessment of the credit quality of the Funds’ counterparties; and (4) monitoring of margin requirements,
position limits and position accountability levels. Additionally, the program provides for stress testing, back-testing, internal reporting
and escalation, and periodic review in compliance with Rule 18f-4. Data relating to such functions is made available by a third-party
service provider engaged by the Funds for analysis and monitoring by the Funds’ derivatives risk manager.

Rule
18f-4 mandates VaR calculations for the purposes of estimating potential losses on an instrument or a portfolio (expressed as a percentage
of the value of the portfolio’s net assets) over a specified time horizon at a given confidence level. The rule requires that a
Fund comply with a “relative” VaR test, unless the derivatives risk manager reasonably determines that a designated reference
portfolio does not provide an appropriate reference portfolio for the relative VaR test, taking into account the Fund’s investments,
investment objectives, and strategy. The VaR model used by a Fund for purposes of determining compliance with the relative VaR test must:
(a) take into account and incorporate all significant, identifiable market risk factors associated with the Fund’s investments,
including, as applicable: (i) equity price risk, interest rate risk, credit spread risk, foreign currency risk and commodity price risk;
(ii) material risks arising from the nonlinear price characteristics of the Fund’s investments, including options and positions
with embedded optionality; and (iii) the sensitivity of the market value of the Fund’s investments to changes in volatility; (b)
use a 99% confidence level and a time horizon of 20 trading days; and (c) be based on at least three (3) years of historical market data.

The
Funds’ program manager is required to select each Fund’s designated reference portfolio, which can be either (1) a designated
index,1 or (2) the Fund’s securities portfolio, excluding derivatives transactions, provided
that the Fund’s securities portfolio reflects the markets or asset classes in which the Fund invests (i.e., the markets
or asset classes in which the Fund invests directly through securities and other investments and indirectly through derivatives transactions).
In addition, the appropriateness of the Fund’s designated reference portfolio will be reviewed as necessary, and at least annually
by the program manager.

Taking
into account all significant, identifiable market risk factors associated with each Fund’s investments, the program manager has
selected the following designated reference portfolio for each Fund as follows:

    Fund
    Designated
    Reference Portfolio

    Tradr
    2X Long Innovation ETF
    S&P
    600 High Beta Index

    Tradr
    2X Short TSLA Daily ETF
    BITA
    US Electrical Vehicle High Vol Index

    Tradr
    1.5X Short NVDA Daily ETF
    BITA
    US Semiconductor High Vol Index

    Tradr
    2X Short Innovation Daily ETF
    S&P
    600 High Beta Index

1
The term “designated index” means an unleveraged index that (1) is approved by the program manager for purposes of
the relative VaR test and that reflects the markets or asset classes in which the Fund invests, and (2) is not administered by an organization
that is an affiliated person of the Fund, its investment advisor, or principal underwriter, or created at the request of the Fund or
its investment advisor, unless the index is widely recognized and used.

While
each Fund provides 200% or less of daily long or inverse exposure to their underlying security, these underlying securities are not technically
“indexes.” Therefore, other indexes must be chosen. Ideally the volatility of those indexes should be reasonably similar
to the underlying security on which these Funds are based. In the case of Long Innovation ETF and Short Innovation ETF, each respective
designated reference portfolio approximates the historical return volatility and historical VaR of the S&P 600 High Beta Index. Similarly,
in the case of TSLA Daily ETF and NVDA Daily ETF, the BITA US Electrical Vehicles High Volatility Index and BITA US Semiconductor High
Volatility Index approximates the return volatility and historical VaR of TSLA and NVDA respectively. Each Fund’s designated reference
portfolio qualifies as a designated reference portfolio under Rule 18f-4 as each portfolio (i) is an unleveraged index that reflects
the markets or asset classes in which the Fund invests,

(ii)
is not administered by an organization that is affiliated with the Fund, the Advisor, or the Fund’s principal underwriter, and
(iii) was not created at the request of the Fund or the Advisor.

The
hypothetical example for each Fund is provided under separate cover.

 7. With
                                            respect to each Fund, please supplementally explain: (a) approximately how many counterparties
                                            the Fund expects to use and what percentage of the Fund’s assets, and how much investment
                                            exposure, is expected to be related to each of these of counterparties; and (b) have there
                                            been discussions with potential swap counterparties and what sort of margin requirements
                                            will be needed. Include an analysis of any impact that margin requirements are expected to
                                            have on the ability of the Funds to implement their investment strategies.

Response:
(a) Each Fund generally trades with five or more swap counterparties, each subject to the terms and conditions of an ISDA Master Agreement
published by the International Swaps and Derivatives Association. The Advisor evaluates and monitors the creditworthiness of the Funds’
counterparties in accordance with its counterparty due diligence policies and procedures. At current fund AUM levels, each Fund diversifies
its exposure to swap counterparties and each Fund’s exposure to any single swap counterparty is limited to 20% of its assets. The
limit will come down as the Funds grow in size and the Advisor adds more counterparties.

(b)
The Advisor confirms that it has engaged in discussions with potential swap counterparties, and it does not currently expect any margin
requirements to have a material impact on the implementation of the Funds’ investment strategies. The Advisor margin requirements
vary between 30% and 40% depending on the counterparty such that the initial mark-to-market value of the margin related to the swap value
will be sufficien