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CORRESP
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David W. Freese

Associate

215.963.5862

January 10, 2020

FILED AS EDGAR CORRESPONDENCE

Ms. Rebecca A. Marquigny

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Response letter to comments on the preliminary proxy
statement of The Advisors’ Inner 	Circle Fund III (File Nos. 333-192858 and 811-22920)

Dear Ms. Marquigny:

On behalf of our client, the Advisors’
Inner Circle Fund III (the “Trust”), we are responding to Staff comments regarding the Trust’s preliminary proxy
statement that was filed with the U.S. Securities and Exchange Commission (“SEC”) on December 17, 2019. The proxy statement
relates to the Joint Special Meeting of Shareholders (the “Meeting”) of the Chiron Capital Allocation Fund and the
Chiron SMid Opportunities Fund (each, a “Fund” together, the “Funds”), each a series of the Trust, called
for the purpose of soliciting shareholder approval of a new investment advisory agreement, on behalf of each Fund. The Staff’s
comments and the Trust’s responses are set forth below. Capitalized terms used, but not defined, herein have the same meaning
given to them in the Registrant’s proxy statement.

 1. Comment: Please specify the date by which executed proxy cards must be received by the Trust in order for the
submitting shareholder’s vote to be counted.

Response: The
requested change has been made.

 2. Comment: In the third “Q&A,” please clarify that the terms of the Current Agreement and the New
Agreement, rather than the agreements themselves, are identical.

Response: The
requested change has been made.

 3. Comment: In the sixth “Q&A,” or in another appropriate place, please state the anticipated
cost of solicitation and identify who will pay such cost.

Response: The requested change has
been made.

 4. Comment: Under the section entitled “The Change in Control of Chiron Investment Management, LLC,”
please explicitly state that shareholders are not being asked to approve the Transaction, but rather that shareholders are being
asked to approve the New Agreement.

Response: The requested change has been
made.

 5. Comment: Under the section entitled “Required Vote,” please clarify the actions the Trust may take
if one Fund approves the New Agreement and one does not.

Response: The requested change has been
made.

 6. Comment: (i) Regarding the section entitled “Voting Authority of Chiron Affiliates,”
please explain supplementally the basis for Chiron’s determination that there are no material conflicts of interest that
arise between shareholders unaffiliated with Chiron and Chiron’s officers and employees that own greater than a 1940 Act
Majority of the Chiron SMid Opportunities Fund’s (the “SMid Fund”) outstanding shares. (ii) In that section,
please also either define “Chiron Affiliates” or revise to lowercase.

Response: (i) Chiron’s
proxy voting policies and procedures govern the manner in which Chiron itself votes proxies relating to portfolio securities held
by its investment advisory clients, including the Funds, when such clients delegate proxy voting authority to Chiron. Chiron’s
proxy voting policies and procedures do not govern the manner in which Chiron’s officers or employees vote proxies relating
to securities held in their personal accounts, including shares of the Funds. Chiron has represented to the Trust that it has not
directed its officers and employees to vote for or against, or abstain from voting on, the Proposal. Chiron itself does not own
any shares of the Fund and, therefore, will not be voting on the Proposal. Therefore, Chiron believes that, under its proxy voting
policies and procedures, no material conflicts of interest arise between shareholders unaffiliated with Chiron and Chiron with
respect to the Proposal. To the extent that a potential material conflict of interest may be deemed to arise between shareholders
unaffiliated with Chiron and Chiron’s officers and employees that own greater than a 1940 Act Majority of the SMid Fund’s
outstanding shares, Chiron believes the appropriate mitigation of this potential conflict is to disclose to shareholders the existence
of this conflict and the amount of the SMid Fund’s shares held by Chiron’s officers and employees. To that end, the
Fund has added the following sentence to the Proxy Statement in the section entitled “Voting Authority of Chiron Affiliates”
following the disclosure informing shareholders of the amount of shares owned by Chiron’s officers and employees: “Certain
of these Chiron officers and employees will receive a financial benefit in connection with the closing of the Transaction, and
the approval of the New Agreement with respect to each Fund is a condition precedent to the closing of the Transaction.”

(ii) The requested change has been made.

 7. Comment: Under the section entitled “Information on Investment Advisory Fees Paid,” please disclose,
if accurate, that the contractual fee waiver in place for the Chiron SMid Opportunities Fund will remain in place if shareholders
of that Fund approve the New Agreement.

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Response: The requested change has been
made.

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If you have any questions, need any additional information or would
like any clarification, please contact me at (215) 963-5862.

Sincerely,

/s/ David W. Freese

David W. Freese

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