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April 14, 2020

Ms. Deborah O’Neal Johnson

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Comments on Post-Effective Amendment filed on behalf of Cognios Large Cap Value Fund and Cognios Market Neutral Large Cap Fund (the “Funds”), each a series of M3Sixty Funds Trust (the “Trust”) (File Nos. 333-206491 and 811-23089)

Dear Ms. O’Neal Johnson:

This letter provides
the Trust’s responses to the comments you provided on Monday, April 6, 2020, as it relates to the post-effective amendment
to the Trust’s registration statement, which was filed on behalf of the Funds on Tuesday, February 18, 2020. For your convenience,
I have summarized the comments in this letter and provided the Trust’s response below each comment.

General

 1. Comment: For the Principal Risks section, please consider
whether the Funds need to provide any disclosures relating to COVID-19. If not, please explain in this response letter why such
disclosure is not needed.

Response: The Trust added
risk disclosure to the statutory prospectus. While the market turmoil caused by COVID-19 has severely impacted the Fund’s
investments, the Trust does not view this risk as an ongoing, principal risk. Rather, it is a unique, health-care related risk
that is not unique to the Fund or its investments.

Summary
Prospectus

 2. Comment: Regarding the expense limitation agreement disclosed
in footnote 1 to the fee table for each Fund, we note that the disclosures states that the recoupment period begins at the end
of the fiscal year in which the waiver or reimbursement occurs. Consistent with the Funds’ proxy statement and expense limitation
agreement, please update the disclosure to state the that recoupment period begins on the date when the waiver or reimbursement
occurs, not the fiscal year end.

Response: The Trust has
updated the disclosure.

 3. Comment: For both Funds, please update the expense example
table from the effective date of the post-effective amendment.

Response: The Trust has updated
the example.

 4. Comment: For the Performance section of both Funds, please
consider whether you need disclosure regarding the change in the adviser and if such a change will have an impact on the Funds’
performance.

Response: The Trust has
updated the disclosure to note the transaction.

Statutory
Prospectus

 5. Comment: For the Prior Performance section, because the adviser
and its portfolio managers have undergone a transaction to a new adviser firm, the Funds need to update the disclosure to include
the requirements of the Bramwell Growth Fund no-action letter and not the Nicholas Applegate no-action letter. Specifically, the
Funds should:

 a. Confirm that all substantially similar accounts were included in
the composite performance;

 b. Confirm that the portfolio managers were the only persons primarily
responsible for the entire performance;

 c. State whether the portfolio managers have the same degree of discretion
at the new adviser or discuss any differences;

 d. Confirm that sales loads have been deducted; and

 e. Confirm in this response letter that the new investment adviser has
the records to support the data, as required by Rule 204-2 under the Investment Advisers Act of 1940.

Response:           The
Trust has updated the prior performance disclosure to comply with the requirements under the Bramwell Growth Fund no-action letter.
The Trust confirms that the portfolio managers can comply with the Bramwell no-action letter.

Please contact me
at (509) 279-8202 if you have any questions or comments on the responses contained in this letter.

    Sincerely,

    /s/ Bo James Howell

    Bo J. Howell

    Partner

    Practus LLP