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 INVESTMENT MANAGERS SERIES TRUST II

 235 W. Galena Street

 Milwaukee, Wisconsin 53212

 VIA EDGAR

 July 18, 2025

 Ms. Mindy Rotter, Esq., CPA

 Ms. Soo Im-Tang

 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”)

 Registration Statement on Form N-14
(File No. 333-287934)

 Dear Ms. Rotter
and Ms. Im-Tang:

 This letter summarizes the comments provided to
me by Ms. Rotter of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
by telephone on July 1, 2025, and by Ms. Im-Tang of the Staff of the Commission by telephone on July 8, 2025, on the Registrant’s
registration statement filed on Form N-14 (the “Registration Statement”) relating to the proposed reorganization of the Redwood
Managed Volatility Fund, Redwood Managed Municipal Income Fund, Redwood AlphaFactor ® Tactical International Fund,
and Redwood Systematic Macro Trend (“SMarT ® ”) Fund (each, a “Target Fund” and together, the
“Target Funds”), each a series of Two Roads Shared Trust, into the Redwood Managed Volatility Fund, Redwood Managed Municipal
Income Fund, Redwood AlphaFactor ® Tactical International Fund, and Redwood Systematic Macro Trend (“SMarT ® ”)
Fund (each, an “Acquiring Fund” and together, the “Acquiring Funds”), respectively, each a newly created
series of the Registrant. This combined proxy statement/prospectus is referred to below as the “Proxy Statement.” The Target
Funds and the Acquiring Funds are collectively referred to herein as the “Funds.”

 Responses to all of the comments are included
below and, as appropriate, will be incorporated into a pre-effective amendment to the Registration Statement (the “Amendment”),
which will be filed separately. Capitalized terms not otherwise defined in this letter have the meanings assigned to them in the Registration
Statement.

 Accounting
Comments

 1. Please confirm in correspondence that the semi-annual financial information will be updated in the Amendment
and all applicable sections and hyperlinks will be updated. In addition, please confirm that an updated auditor consent will be provided.

 Response : The Registrant confirms
that the semi-annual financial information and all applicable sections and hyperlinks will be updated in the Amendment. In addition, the
Registrant confirms that the Amendment will contain an updated auditor consent.

 2. Please explain the source for the fees and expenses presented for all Target Fund share classes. The Staff
notes that the fees for each Acquiring Fund share class appear to correspond to the Form N-1A filing filed on March 20, 2025.

 Response : The Registrant confirms
that the source for the fees for all Target Fund share classes and Acquiring Fund share classes is as of April 30, 2025. Please see the
revised fee tables in Appendix A attached hereto.

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 3. Please update the fees to represent current fees in accordance with Item 3 in Form N-14.

 Response : The Registrant has
updated the fee tables to reflect information as of April 30, 2025. The Registrant believes that the fees presented in the fee tables
represent current fees, as required by Item 3(a) of Form N-14. Please see the revised fee tables in Appendix A attached hereto.

 4. Please confirm in your correspondence filing whether the Adviser’s right of recoupment of fee waivers
and expense reimbursements made with respect to the Target Funds will survive the Reorganization. If yes, please confirm such expenses
will not be carried over to the merged entities.

 Response : The Registrant confirms
that Redwood will not seek recoupment of fees waived and expense reimbursement made by Redwood to the Target Funds prior to the Reorganizations.

 5. Please consider updating the capitalization table to reflect data from within 30 days of the filing of
the Amendment or alternatively, confirm in correspondence that there have been no material changes to the capitalization table since the
date reflected in the table.

 Response : The Registrant has
updated the capitalization table to reflect data as of June 30, 2025, and confirms that the updated capitalization table will be included
in the Amendment. Please see the revised capitalization tables in Appendix B attached hereto.

 6. On page v of the Proxy Statement, it states “[s]ince October 31, 2024, the Redwood Managed Municipal
Income Fund (Target Fund) has had no Class N Shares outstanding. The Redwood Managed Municipal Income Fund (Acquiring Fund) does not currently
intend to offer Class N Shares.” Please include this footnote regarding Class N shares with respect to the Redwood Managed Municipal
Income Fund as a footnote to the capitalization table.

 Response: The Registrant has added the
disclosure as a footnote to the capitalization table for the Redwood Managed Municipal Income Fund. Please see the revised capitalization
table in Appendix B attached hereto.

 Legal Comments

 7. In the Dear Shareholder letter included in the Proxy Statement, it states “[t]he Reorganizations
are not expected to result in any increases in shareholder fees or expenses.” Please clarify in the disclosure if there will be
any increase and if so, explain the increase.

 Response : The Registrant has
revised the disclosure as follows:

 The Reorganizations are not expected
to result in any increases in shareholder fees or expenses. The management fee of each Acquiring Fund is the same as the management
fee of its corresponding Target Fund and, following
the Reorganization, the net total annual fund operating expenses (after waiving fees and/or reimbursing expenses, as applicable) of each
Acquiring Fund are expected to be the same as or lower than those of its corresponding Target Fund.

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 8. In the Dear Shareholder letter included in the Proxy Statement, it states “[a]fter careful consideration,
for the reasons discussed in the attached Proxy Statement/Prospectus, and based on the recommendation of the Target Funds’ investment
adviser, Redwood, as well as in reliance upon certain representations and commitments made by Redwood to the Board, the Board has approved
the Reorganizations and the solicitation of the Target Funds’ shareholders with respect to the Reorganization Agreement.”
Please add that the Board unanimously approved the Reorganizations to be consistent with the disclosure contained in the Proxy Statement.

 Response : The Registrant has
revised the disclosure as follows:

 After careful consideration, for the
reasons discussed in the attached Proxy Statement/Prospectus, and based on the recommendation of the Target Funds’ investment adviser,
Redwood, as well as in reliance upon certain representations and commitments made by Redwood to the Board, the Board has unanimously
approved the Reorganizations and the solicitation of the Target Funds’ shareholders with respect to the Reorganization Agreement.

 9. Please add disclosure to the Dear Shareholder letter to indicate that the Board, including the independent
trustees, unanimously recommends that shareholders of each Target Fund approve the Reorganization Agreement and the Reorganization.

 Response : The Registrant acknowledges
the Staff’s comment and respectfully declines to add the requested disclosure. The Registrant believes that the current disclosure
is appropriate.

 10. In the Notice of Special Meeting of Shareholders, please define June 16, 2025, as the “Record Date.”

 Response : The Registrant has
revised the disclosure as follows:

 Only shareholders of record of the
Target Funds at the close of business on June 16, 2025 (the “Record Date”) , the record date for this Special Meeting,
will be entitled to notice of, and to vote at, the Special Meeting or any postponements or continuations after an adjournment thereof.

 11. In the Question and Answer regarding “ How will each Reorganization work? ”, please clarify
that immediately after the Reorganization, each shareholder of the Target Fund will hold a number of full and fractional shares of the
Acquiring Fund equal in aggregate net asset value at the time of the exchange to the aggregate net asset value of such shareholder’s
shares of the Target Fund immediately prior to the Reorganization.

 Response : The Registrant has
revised the disclosure as follows:

 Shareholders of the Target Fund will
become shareholders of the Acquiring Fund, and immediately after the Reorganization each such shareholder will hold a number of full and
fractional shares of the Acquiring Fund equal in aggregate net asset value at the time of the exchange to the aggregate net
asset value of such shareholder’s shares of the Target Fund immediately prior to the Reorganization.

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 12. In the Question and Answer regarding “ How will each Reorganization work? ”, please add
to the footnote to the table that there are no investors in Class N shares of the Redwood Managed Municipal Income Fund (Target Fund).

 Response : The Registrant has revised the table and
footnote as follows:

 The chart below indicates which Acquiring Fund share class
you will receive in a Reorganization, depending on which Target Fund share class you currently own:

 Trust

 IMST II

 Redwood Managed Volatility Fund

 Redwood Managed Volatility Fund

 Class I Shares
 Class N Shares
 Class Y Shares

 →
 →
 →

 Class I Shares
 Class N Shares
 Class Y Shares

 Redwood Managed Municipal Income Fund

 Redwood Managed Municipal Income Fund

 Class I Shares
 Class N Shares *
 →

 Class I Shares
 N/A*

 Redwood AlphaFactor® Tactical International Fund

 Redwood AlphaFactor® Tactical International Fund

 Class I Shares
 Class N Shares

 →
 →

 Class I Shares
 Class N Shares

 Redwood Systematic Macro Trend (“SMarT ® ”) Fund

 Redwood Systematic Macro Trend (“SMarT ® ”) Fund

 Class I Shares
 Class N Shares

 →
 →

 Class I Shares
 Class N Shares

 * Since October 31, 2024, there have been no investors in Class N Shares of the Redwood Managed Municipal
Income Fund (Target Fund) , and the Fund has had no Class N Shares outstanding. The Redwood Managed Municipal Income
Fund (Acquiring Fund) does not currently intend to offer Class N Shares.

 13. In the Question and Answer regarding “ How will the proposed Reorganization affect the fees and
expenses I pay as a shareholder of a Target Fund? ”, please revise the disclosure to state that following the Reorganizations,
the total gross annual fund operating fees and expenses of each Acquiring Fund, before any applicable waivers and/or expense reimbursements,
are expected by the Adviser to be lower than those of the corresponding Target Fund.

 Response : The Registrant has
revised the disclosure as follows:

 The management fee of each Acquiring
Fund is the same as the management fee of tis corresponding Target Fund and, following the Reorganization, the net total annual fund operating
fees (after waiving fees and/or reimbursing expenses, as applicable) of each Acquiring Fund are expected to be the same as of lower than
those of the corresponding Target Fund.

 14. In the Question and Answer regarding “ Who is paying for expenses related to the Special Meeting
and the Reorganizations? ”, please add disclosure that Redwood or any affiliate will bear the costs and expenses incurred in
connection with the Reorganizations, whether or not the Reorganizations are consummated. Additionally, please disclose the estimated direct
expenses to be incurred by Redwood.

 Response : The Registrant
confirms that the estimated direct expenses to be incurred by Redwood will be included in the definitive Proxy Statement.

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 15. In the Question and Answer regarding “ How do I cast my vote? ”, please add disclosure
that a proxy solicitor is to be used, as well as their contract and their costs.

 Response : The Registrant has
added the following disclosure:

 Redwood has engaged Sodali &
Co. to provide shareholder meeting services, including the distribution of this Proxy Statement and related materials to shareholders,
as well as assist the Target Funds in soliciting proxies for the Special Meeting at an anticipated cost of approximately $108,481 .

 16. Under “Comparison of Investment Restrictions”, please specify which fundamental investment
policies apply to which Funds or make clear that the policies apply to all Funds.

 Response : The Registrant notes
that the table specifies that each fundamental policy applies to each Target Fund and each Acquiring Fund, except for the Names Policy,
which applies only to the Redwood Managed Municipal Income Funds.

 17. In the comparison of non-fundamental investment restrictions, please specify which non-fundamental investment
policies apply to which Funds or make clear that the policies apply to all Funds.

 Response : The Registrant has
revised the disclosure as follows:

 The Funds observe the following
non-fundamental investment restrictions applicable to each Target Fund and each Acquiring Fund are noted in the following table .

 18. Under “Distribution Fees” in the table in the “Distribution Fees, Shareholder Service
Fees, Additional Payment to Broker-Dealers and Other Financial Intermediaries” section, please add for the Acquiring Funds that
the Redwood Managed Municipal Income Fund does not intend to offer Class N shares.

 Response : The Registrant has
added the following disclosure:

 The Redwood Managed Municipal
Income Fund does not currently intend to offer Class N shares.

 19. Under “Shareholder Service Fees” in the table in the “Distribution Fees, Shareholder
Service Fees, Additional Payments to Broker-Dealers and Other Financial Intermediaries” section, please disclose the fee rate for
the Target Funds.

 Response : The Registrant has
revised the disclosure as follows:

 The Target Funds may make
payments to certain shareholder servicing agents, and such payments are referred to in the Target Funds’ financial statements
as third party administrative service fees. Each Target Fund may pay a third party administrative service fee at an annual rate
of up to 0.15% of its average daily net assets.

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 20. Under “Background and Trustees’ Considerations Relating to the Proposed Reorganization”,
please clarify why the Board considered the Reorganization in the first place (i.e., were the Funds losing assets or were there other
issues?). Did the Board consider the Funds’ performance? If so, please add disclosure to the discussion.

 Response : The Registrant confirms
that the Board initially considered the Reorganization due to a proposal from Redwood, the adviser of each Target Fund and proposed adviser
of each Acquiring Fund, that the Target Funds be reconstituted as series of IMST II. The Registrant notes this is disclosed in the first
sentence of the section, “Background and Trustees’ Considerations Relating to the Proposed Reorganization” and considers
the current disclosure to be sufficient as it also includes a discussion of the Adviser’s rationale for the Reorganizations. The
Registrant also notes that the current disclosure states that the Board considered the historical performance of each Target Fund in determining
whether to approve the Reorganization.

 21. In the sentence which reads, “[i]n reaching its decision to approve the Reorganizations, the Board
concluded, in reliance upon the representations and commitments by Redwood to the Board, including with respect to actions taken or to
be taken by Redwood, that the participation of the Target Funds in the Reorganizations is in the best interests of each Target Fund and
that the interests of existing shareholders of each Target Fund would not be diluted as a result of the Reorganization”, please
consider whether it would be appropriate to disclose such representations and commitments here.

 Response : The Registrant has
revised the disclosure as follows:

 In reaching its decision to approve
the Reorganizations, the Board concluded,