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INVESTMENT MANAGERS SERIES TRUST II

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

February 16, 2023

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” or “Trust”) on behalf of the AXS Dynamic Opportunity
Fund and AXS Tactical Income 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
24, 2023, regarding Post-Effective Amendment No. 373 to the Registrant’s registration statement filed on Form N-1A (the “Registration
Statement”) on December 12, 2022, relating to the AXS Dynamic Opportunity Fund and AXS Tactical Income Fund (each, a “Fund”
and together, the “Funds”), each a newly-created series of the Trust. Responses to all
of the comments are included below and, as appropriate, will be reflected in a Post-Effective Amendment to the Funds’ 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.

GENERAL

 1. Please confirm in your written response that the Registrant intends to file a Registration Statement on
Form N-14 regarding the reorganization of the ACM Dynamic Opportunity Fund into the AXS Dynamic Opportunity Fund, and the reorganization
of the ACM Tactical Income Fund into the AXS Tactical Income Fund (the “Form N-14 Registration Statement”). In addition, please
confirm that the comments given on the Registration Statement will be made to the Form N-14 Registration Statement, as applicable.

Response: The Registrant confirms
that the initial Form N-14 Registration Statement was filed with the Commission on February 8, 2023 (SEC Accession No. 0001398344-23-002385),
and that all applicable comments given on the Registration Statement will be incorporated into the final Form N-14 Registration Statement.

 2. Please confirm that the Prospectus and Statement of Additional Information for each Fund will not be used
to offer shares to investors until after the applicable reorganization is completed.

Response: The Registrant so confirms.

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 3. Please provide the Funds’ ticker symbols with the filing of the Amendment.

Response: The Registrant confirms that the Funds’
ticker symbols will be incorporated into the Amendment.

SUMMARY SECTION

Fees and Expenses Tables and Example

 4. Please provide the Funds’ completed fees and expenses tables and examples for the Commission’s review at least five business
days prior to filing the Amendment.

Response: The Funds’ completed
fees and expenses tables and examples, which will be included in the Amendment, are as follows:

AXS Dynamic Opportunity Fund

    Class

    A

    Shares

    Class

    I

    Shares

    Shareholder Fees

    (fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases (as a percentage of offering price)
    5.75%
    None

    Maximum deferred sales charge (load) (as a percentage of the lesser of the value redeemed or the amount invested)
    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 and service (Rule 12b-1) fees
    0.25%
    None

    Other expenses1
    0.43%
    0.43%

    Short Selling Dividend and Interest Expense
    0.06%
    0.06%

    Other Expenses
    0.37%
    0.37%

    Total annual fund operating expenses2
    1.93%
    1.68%

 1 “Other Expenses”
for the Fund have been estimated for the current fiscal year. Actual expenses may differ from estimates.

 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 2.40% and 2.15% of the average daily net assets of Class A and Class I shares of the Fund, respectively. This
agreement is in effect for a period of two years from the date of the reorganization of the ACM Dynamic Opportunity Fund, a series of
Northern Lights Fund Trust III, which is expected to occur during the second quarter of 2023, 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 by the advisor to the Fund for a period ending three 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 Class
A shares or Class I shares of 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

    Class A Shares
    $760
    $1,146
    $1,557
    $2,699

    Class I Shares
    $171
    $530
    $913
    $1,987

AXS Tactical Income Fund

    Class

    A

    Shares

    Class

    I

    Shares

    Shareholder Fees

    (fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases (as a percentage of offering price)
    5.75%
    None

    Maximum deferred sales charge (load) (as a percentage of the lesser of the value redeemed or the amount invested)
    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
    1.00%
    1.00%

    Distribution and service (Rule 12b-1) fees
    0.25%
    None

    Other expenses1
    0.43%
    0.43%

    Acquired fund fees and expenses1
    1.27%
    1.27%

    Total annual fund operating expenses2
    2.95%
    2.70%

 1 “Other Expenses”
and “Acquired fund fees and expenses” for the Fund have been estimated for the current fiscal year. Actual expenses may differ
from estimates.

 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 2.25% and 2.00% of the average daily net assets of Class A and Class I shares of the Fund, respectively. This
agreement is in effect for a period of two years from the date of the reorganization of the ACM Tactical Income Fund, a series of Northern
Lights Fund Trust III, which is expected to occur during the second quarter of 2023, 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 by the advisor to the Fund for a period ending three 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.

    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 Class
A shares or Class I shares of 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

    Class A Shares
    $856
    $1,435
    $2,038
    $3,658

    Class I Shares
    $273
    $838
    $1,430
    $3,032

Performance

 5. Please update the performance information in the bar chart and table for each Fund with the applicable Predecessor Fund’s performance
information, and provide the updated performance information for the Commission’s review at least five business days prior to filing
the Amendment.

Response: The Registrant has updated
each Fund’s performance information, which will be included in the Amendment, as follows:

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AXS Dynamic Opportunity Fund

Calendar-Year Total Return (before taxes) for Predecessor
Fund Class I Shares

For each calendar year at NAV

    Highest Calendar Quarter Return at NAV
    11.51%
    Quarter Ended 9/30/2020

    Lowest Calendar Quarter Return at NAV
    (8.67)%
    Quarter Ended 12/31/2018

    Average Annual Total Returns

    (for periods ended December 31, 2022)

    1 Year
    5 Years

    Since Inception

    (1/20/2015)

    Class I - Return Before Taxes
    (12.79)%
    1.78%
    3.33%

    Class I - Return After Taxes on Distributions
    (14.06)%
    1.09%
    2.89%

    Class I - Return After Taxes on Distributions and Sale of Fund Shares*
    (6.65)%
    1.39%
    2.62%

    Class A – Return Before Taxes
    (17.98)%
    0.38%
    2.36%

    S&P 500 Total Return Index (reflects no deduction for fees, expenses or taxes)1
    (18.11)%
    9.42%
    10.48%

    HFRX Equity Hedge Index (reflects no deduction for fees, expenses or taxes)2
    (3.18)%
    2.63%
    2.68%

    S&P 500 (Price) Index (reflects no deduction for fees, expenses or taxes)3
    (19.44)%
    7.51%
    8.40%

* After-tax returns are calculated using the historical highest individual federal marginal income tax rates
and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ
from those shown. After-tax returns shown are not relevant to investors who hold their Fund shares through tax-deferred arrangements,
such as 401(k) plans or individual retirement accounts. After-tax returns are shown for Class I Shares only and after-tax returns for
classes other than Class I will vary from returns shown for Class I.

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1 The S&P 500 Total Return Index is a market capitalization-weighted index of 500 widely held common
stocks. Investors cannot invest directly in an index.

2 The HFRX Equity Hedge Index is an index managed by Hedge Fund Research, Inc. (“HFR”). HFR
is the established global leader in the indexation, analysis and research of the hedge fund industry. With over 150 indices ranging from
broad composites down to specific, niche areas of sub-strategy and regional investment focus, the HFRX Indices are considered the industry
standard benchmarks of hedge fund performance. The HFRX branded indices are daily indices utilizing a rigorous quantitative selection
process to represent the larger hedge fund universe. Investors cannot invest directly in an index.

3 The S&P 500 Price Index is a stock market index that measures the stock performance of 500 large companies
listed on the stock exchange. Investors cannot invest directly in an index.

AXS Tactical Income Fund

Calendar-Year Total Return (before taxes) for Predecessor
Fund Class I Shares

For each calendar year at NAV

    Highest Calendar Quarter Return at NAV
    4.18%
    Quarter Ended 6/30/2020

    Lowest Calendar Quarter Return at NAV
    (2.93)%
    Quarter Ended 6/30/2022

    Average Annual Total Returns

    (for periods ended December 31, 2022)

    1 Year

    Since Inception

    (12/31/2018)

    Class I - Return Before Taxes
    (7.66)%
    0.98%

    Class I - Return After Taxes on Distributions
    (8.56)%
    (0.32)%

    Class I - Return After Taxes on Distributions and Sale of Fund Shares*
    (4.47)%
    0.26%

    Class A – Return Before Taxes
    (13.21)%
    (0.74)%

    Bloomberg U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) 1
    (13.01)%
    0.03%

* After-tax returns are calculated using the historical highest individual federal marginal income tax rates
and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ
from those shown. After-tax returns shown are not relevant to investors who hold their Fund shares through tax-deferred arrangements,
such as 401(k) plans or individual retirement accounts. After-tax returns are shown for Class I Shares only and after-tax returns for
classes other than Class I will vary from returns shown for Class I.

    6

1 The Bloomberg U.S. Aggregate Bond Index is an unmanaged index comprised of U.S. investment grade, fixed
rate bond market securities, including government, government agency, corporate and mortgage-backed securities between one and ten years.
Investors cannot invest directly in an index.

* * * * *

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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