SecProbe.io

CORRESP
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filename1.htm

Christine M. Nassauer

Associate

+1.215.963.4660

christine.nassauer@morganlewis.com

February 21,
2020

FILED AS
EDGAR CORRESPONDENCE

Rebecca Marquigny,
Esq.

U.S. Securities
and Exchange Commission

100 F Street,
NE

Washington,
D.C. 20549

Re: The Advisors’
Inner Circle Fund III 485(a) Filing (File Nos. 333-192858 and 811-22920)

Dear Ms. Marquigny:

On behalf of our client, The Advisors’
Inner Circle Fund III (the “Trust”), this letter responds to the comments you provided on behalf of the staff (the
“Staff”) of the Securities and Exchange Commission (the “SEC”) via telephone, regarding the Trust’s
post-effective amendment no. 224, under the Securities Act of 1933, as amended (the “1933 Act”), and amendment no.
228, under the Investment Company Act of 1940, as amended (the “1940 Act”), to its registration statement filed with
the SEC pursuant to Rule 485(a) under the 1933 Act (the “Amendment”) with respect to the Fiera Capital Diversified
Alternatives Fund (the “Fund”). Below, we have briefly summarized your comments and questions, followed by our responses.
Capitalized terms not defined herein should be given the meaning provided in the Amendment.

Comments
on the Prospectus

 1. Comment.	Please provide the “Annual Fund Operating Expenses” table
and “Example” figures that will be included in the Prospectus.

  Response.	The following “Annual
Fund Operating Expenses” table and “Example” figures will be included in the Prospectus:

   Morgan, Lewis & Bockius llp

   1701 Market Street

   Philadelphia, PA 19103-2921

   United States

   +1.215.963.5000

     +1.215.963.5001

Rebecca Marquigny, Esq.

February 21, 2020

Page 2

Annual Fund Operating Expenses (expenses
that you pay each year as a percentage of the value of your investment)

    Investor Class Shares
    Institutional Class Shares

    Management Fees

    1.75%

    1.75%

    Distribution (12b-1) Fees

    0.25%

    None

    Other Expenses

    1.38%

    1.38%

        Dividend and Interest Expenses on Securities Sold
Short

    0.25%

    0.25%

    Shareholder Servicing Fees
    —1

    None

    Other Operating Expenses
    1.13%

    1.13%

    Acquired Fund Fees and Expenses

    0.11%

    0.11%

    Total Annual Fund Operating Expenses

    3.49%

    3.24%

    Less Fee Reductions and/or Expense Reimbursements2

    (0.38)%

    (0.38)%

    Total Annual Fund Operating Expenses after Fee Reductions and/or Expense Reimbursements

    3.11%

    2.86%

                                                   1

 Amounts designated as "—" are zero or have been rounded to zero.

 2 Fiera Capital Inc. (the “Adviser”) has contractually agreed to reduce fees and reimburse
expenses to the extent necessary to keep Total Annual Fund Operating Expenses after Fee Reductions and/or Expense Reimbursements
(excluding any class-specific expenses, Dividend and Interest Expenses on Securities Sold Short, interest, taxes, brokerage commissions
and other costs and expenses relating to the securities that are purchased and sold by the Fund, Acquired Fund Fees and Expenses,
other expenditures which are capitalized in accordance with generally accepted accounting principles, and non-routine expenses
(collectively, “excluded expenses”)) from exceeding 2.50% with respect to Investor Class shares and Institutional Class
shares of the Fund’s average daily net assets until February 28, 2021 (the “Expense Limitation”). The Adviser
may receive from the Fund the difference between the Total Annual Fund Operating Expenses (not including excluded expenses) and
the Expense Limitation to recoup all or a portion of its prior fee reductions or expense reimbursements made during the rolling
three-year period preceding the date of the recoupment if at any point Total Annual Fund Operating Expenses (not including excluded
expenses) are below the Expense Limitation (i) at the time of the fee reduction and/or expense reimbursement and (ii) at the time
of the recoupment. This agreement may be terminated: (i) by the Board of Trustees (the “Board”) of The Advisors’
Inner Circle Fund III (the “Trust”) for any reason at any time, or (ii) by the Adviser, upon ninety (90) days’
prior written notice to the Trust, effective as of the close of business on February 28, 2021.

 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 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 (including one year of capped expenses
in each period) remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would
be:

Rebecca Marquigny, Esq.

February 21, 2020

Page 3

    1 Year
    3 Years
    5 Years
    10 Years

    Investor Class Shares
    $314
    $1,036
    $1,780
    $3,740

    Institutional Class Shares
    $289
    $963
    $1,660
    $3,514

 2. Comment.	With respect to the Expense Limitation’s excluded expenses, please
supplementally provide examples of costs and expenses, other than brokerage commissions, that relate to the securities that are
purchased and sold by the Fund.

  Response.	With respect to the Expense
Limitation’s excluded expenses, costs and expenses, other than brokerage commissions, that relate to the securities that
are purchased and sold by the Fund include trading costs such as bid/ask spread and price impact.

 3. Comment.	In the “Principal Investment Strategies” section, please
add “in the chart directly” before “above” in the second to last sentence of the section.

  Response.	 The requested change has
been made.

 4. Comment.	In the “Investment Adviser and Portfolio Managers” and “Investment
Sub-Advisers and Portfolio Managers” sections, please specify the month in which each portfolio manager began managing the
Fund.

  Response.	The requested changes have
been made.

 5. Comment.	Please confirm that the principal investment strategies and risks disclosure
provided in response to Item 4 of Form N-1A appropriately summarizes the principal investment strategies and risks disclosure provided
in response to Item 9 of Form N-1A.

  Response.	The Trust confirms that the
principal investment strategies and risks disclosure provided in response to Item 4 of Form N-1A appropriately summarizes the
principal investment strategies and risks disclosure provided in response to Item 9 of Form N-1A.

* * * * * * * * * * * *

If you have any questions, need any additional
information or would like any clarification, please contact me at (215) 963-4660.

Very truly yours,

/s/ Christine M. Nassauer

Christine M. Nassauer