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KBL Merger Corp. IV

527 Stanton Christiana Road

Newark, DE 19713

    May 23, 2017

Via
EDGAR

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Mail
Stop 3030

Washington,
D.C. 20549

Attn:
Russell Mancuso

    Re:
    KBL
    Merger Corp. IV

Amendment
No. 1 to Registration Statement on Form S-1

Filed
May 17, 2017

File
No. 333-217475

Dear
Mr. Mancuso:

On
behalf of KBL Merger Corp. IV, a Delaware corporation (the “Company”), we hereby transmit the Company’s
response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”) on May 15, 2017, regarding Amendment No. 1 to the Form S-1 filed with the Commission on
April 26, 2017 (the “Registration Statement”).

For
the Staff’s convenience, we have repeated below the Staff’s comments in bold and have followed each comment with the
Company’s response.

Transfer
of Founder Shares and Private Placement Units, page 104

 1. Please
                                         tell us which section of which exhibit requires transferees to be bound by the provisions
                                         that you mention in your revisions made in response to prior comment 8. Also, from those
                                         revisions, it appears that your securities could be transferred in accordance with your
                                         sponsor's LLC agreement or in connection with a liquidation, and the agreements regarding
                                         voting, the trust account, and liquidation distributions would not apply to the transferees.
                                         If so, please clearly explain in your risk factors and highlight the risk in your prospectus
                                         summary.

Please
be advised that Section 7(c) of Exhibit 10.2 requires transferees to be bound by the provisions mentioned in prior comment 8.
In response to the Staff’s comment, we have revised the disclosure on pages 104 and 105 of the Registration Statement to
remove the old reference to (h) since that already constitutes a release from restriction of transfer pursuant to clause (y) in
the same paragraph. In addition, we added a new clause (g), pursuant to which the holders may transfer shares back to the Company
for no value for cancellation. We have made the corresponding adjustments to Section 7(c) of the Letter Agreement attached as
Exhibit 10.2 to the Registration Statement. In light of the changes described herein, we do not believe a separate risk factor
is required.

Exhibit
1.1

 2. The
                                         contingency in paragraph 4.7 of exhibit 1.1 appears to create an offering that is other
                                         than a firm commitment. We also note the related representations in paragraph 2.21.2.
                                         It is unclear whether the underwriters will be collecting funds prior to that contingency
                                         being satisfied. If so, please tell us whether the underwriters will comply with Rule
                                         15c2-4. Also, provide us your analysis supporting your conclusion that Rule 419 is not
                                         applicable to this offering; see Release 33-7024 (October 25, 1993).

In
response to the Staff’s comment, we have deleted paragraph 4.7 of Exhibit 1.1 and have clarified in the
opening sentence of Section 4 that the portion of paragraph 2.21.2 that pertains to the underwriters’ consummation of
the purchase of their share of the Placement Units is not a closing condition. The revised version of the Underwriting
Agreement is being filed as an exhibit to the Registration Statement. With regard to Rule 419, the Company will be required
to file a Form 8-K, promptly after the closing of the offering, which will contain an audited balance sheet reflecting
net tangible assets upon successful completion of the offering in excess of $5,000,000. The Company will therefore be
exempt from Rule 419.

We
thank the Staff in advance for its consideration of the Registration Statement. Should you have any questions regarding the foregoing,
please contact Stuart Neuhauser, Esq. of Ellenoff Grossman & Schole LLP at (212) 370-1300.

    Sincerely,

    /s/
    Marlene Krauss

    Marlene
    Krauss

    cc:

    Ellenoff
    Grossman & Schole LLP

    Holland
& Knight LLP