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INVESTMENT MANAGERS SERIES TRUST II

235 W. Galena Street

Milwaukee, Wisconsin 53212

VIA EDGAR

March 14, 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”)

Registration
Statement on Form N-14 (File No. 333-269643)

Ladies and Gentlemen:

This letter summarizes the comments provided to me
by Mr. Tony Burak of the staff of the Securities and Exchange Commission (the “Commission”) by telephone on March 6, 2023,
and Mr. David Orlic of the staff of the Commission by telephone on March 7, 2023, on the Registrant’s registration statement filed
on Form N-14 (the “Registration Statement”) relating to the proposed reorganization of ACM Dynamic Opportunity Fund and ACM
Tactical Income Fund, each a series of the Northern Lights Fund Trust III,
into the AXS Dynamic Opportunity Fund and AXS Tactical Income Fund, each a newly-created series of the Registrant.

Responses to all of the comments are included below
and, as appropriate, will be incorporated into a filing made pursuant to Rule 497 under the Securities Act of 1933. Capitalized terms
not otherwise defined in this letter have the meanings assigned to them in the Registration Statement.

Questions & Answers

 1. In the last sentence to the response to the question “Who will manage the Acquiring Funds?” please correct the
name for the portfolio manager as it appears his first name is duplicated.

Response: The Registrant has corrected
the disclosure as requested.

 2. The response to the question “How will the proposed reorganization affect the fees and expenses I pay as a shareholder of
the Acquired Fund?” indicates that total annual fund operating expenses and fees of each Acquiring Fund are expected to be lower
(before and after fee waivers) than those of the corresponding Acquired Fund. Given that each Acquiring Fund will have the same fee waivers
in place as those of the corresponding Acquired Fund, please revise the disclosure to indicate that the fees for the Acquiring Funds are
expected to be the same as or lower than those of the Acquired Funds.

Response: The Registrant confirms
that each Acquiring Fund will have the same fee waivers in place as those of the corresponding Acquired Fund. The Registrant notes, however,
that (i) each Acquired Fund’s total annual fund operating expenses are currently below the Acquired Fund’s expense cap and
each Acquiring Fund’s total annual fund operating expenses are also expected to operate below the Acquiring Fund’s expense
cap; and (ii) each Acquiring Fund’s total annual fund operating expenses are expected to be below the corresponding Acquired Fund’s
current total annual fund operating expenses. To clarify, the Registrant has revised the first paragraph of the response as follows:

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Each Acquiring Fund will pay the same annual
advisory fee rate currently paid by the corresponding Acquired Fund. Following the Reorganizations, the total annual fund operating fees
and expenses of each Acquiring Fund are expected to be the lower (before and after fee waivers)
than those of the corresponding Acquired Fund.

Combined Proxy Statement/Prospectus

 3. The staff notes that the fee tables and examples show the fees and expenses of the Acquired Funds as of the semi-annual period ended
October 31, 2022. Please confirm the expenses shown in the fee tables are representative of the current expenses of the Acquired Funds
in accordance with Item 3 of Form N-14. If the fees are significantly different, please update the fee tables to reflect current expenses.

Response: The Registrant confirms
that the fee tables shown for the Acquired Fund reflect the Acquired Funds’ current expenses.

 4. Footnote 2 to the fee tables for the ACM Dynamic Opportunity Fund/AXS Dynamic Opportunity Fund and Footnote 3 to the fee tables for
the ACM Tactical Income Fund/AXS Tactical Income Fund indicate that the Acquired Fund’s advisor has agreed to reduce its fees and/or
reimburse expenses of the Acquired Fund until April 30, 2023, and that the Acquired Fund’s advisor may recoup fees waived or reimbursed
by the Acquired Fund’s advisor for a period of three years after the fees have been waived or reimbursed if such recoupment can
be achieved within the lesser of the Fund’s expense limits and any expense limits in place at time of waiver. Please clarify whether
the Acquired Fund’s advisor will have the ability following the merger to recoup amounts waived or reimbursed by the Acquired Fund’s
advisor prior to the Reorganization.

Response: The Registrant confirms
that the Acquired Funds’ adviser will not have the ability to recoup amounts that it waived prior to the merger. The Registrant
has added the following sentence to Footnote 2 and Footnote 3, as applicable, to each fee table:

The Acquired Fund’s advisor will
not seek recoupment of any previously waived fees following the Reorganization of the Acquired Fund.

 5. Please revise the figures in the Example for each Acquiring Fund’s Class A Shares (Pro Forma)
to reflect the sales load.

Response: The Registrant has revised
the Example as follows:

Example

The Example below is intended to help you
compare the cost of investing in each Acquired Fund with the cost of investing in the corresponding Acquiring Fund on a pro forma basis.
The Example assumes that you invest $10,000 in a Fund and then redeem all of your shares at the end of each period. The Example also assumes
that your investment has a 5% annual return, that each Fund’s Total Annual Fund Operating Expenses remain as stated in the previous
table and that distributions are reinvested. Although your actual costs may be higher or lower, based on these assumptions, your costs
would be as follows, if you redeem your shares:

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    ACM Dynamic Opportunity Fund
    One Year
    Three Years
    Five Years
    Ten Years

    Acquired Fund – Class A Shares
    $761
    $1,149
    $1,562
    $2,709

    Acquiring Fund - Class A Shares (Pro forma)
    $760
    $1,146
    $1,557
    $2,699

    Acquired Fund - Class I Shares
    $172
    $533
    $918
    $1,998

    Acquiring Fund - Class I Shares (Pro forma)
    $171
    $530
    $913
    $1,987

    ACM Tactical Income Fund
    One Year
    Three Years
    Five Years
    Ten Years

    Acquired Fund – Class A Shares
    $864
    $1,458
    $2,076
    $3,730

    Acquiring Fund - Class A Shares (Pro forma)
    $856
    $1,435
    $2,038
    $3,658

    Acquired Fund - Class I Shares
    $281
    $863
    $1,470
    $3,111

    Acquiring Fund - Class I Shares (Pro forma)
    $273
    $838
    $1,430
    $3,032

 6. Please disclose if there are any valuation differences that would cause an adjustment to the assets on
the Reorganization date. If there are valuation differences and the adjustments are material, it should be shown as an adjustment to the
capitalization table.

Response: The Registrant confirms
that there are no valuation differences that would cause an adjustment to the assets on the Reorganization date.

 7. Under “Portfolio Turnover” please update the figures to show the portfolio turnover amounts for 2022.

Response: The Registrant has revised
the disclosure as follows:

During the most recent fiscal year, the
portfolio turnover rate for the ACM Dynamic Opportunity Fund was 742% of the average value of its portfolio, and the portfolio turnover
rate for the ACM Tactical Income Fund was 894% of the average value of its portfolio.

Part C

 8. In future filings, please add disclosure that the opinion of counsel regarding the tax consequences to
shareholders will be filed within a reasonable amount of time after receipt of the opinion.

Response: The Registrant confirms
this language will be added to this undertaking in future filings.

 9. In future filings, please indicate the Ms. Dam is also the Principal Accounting Officer.

Response: The Registrant confirms
that Ms. Dam’s title will reflect that she is the Treasurer, Principal Financial Officer and Principal Accounting Officer in future
filings.

* * * * *

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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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