Northern Lights Fund Trust Iii CORRESPCorrespondence with SEC

Marathon Value Portfolio, Pinnacle Sherman Multi-Strategy Core Fund, Pinnacle TrendRating Innovative Equity Fund, Absolute Capital Asset Allocator Fund, Absolute Capital Defender Fund

Inspire Tactical Balanced ESG ETF, Inspire Faithward Mid Cap Momentum ESG ETF, Inspire Faithward Large Cap Momentum ESG ETF, Anchor Risk Managed Credit Strategies Fund. Anchor Risk Managed Equity Strategies Fund, Anchor Risk Managed Global Strategies Fund, Anchor Risk Managed Municipal Strategies Fund

Navigator Tactical Fixed Income Fund, Navigator Tactical U.S. Allocation Fund

Main BuyWrite Fund, Anchor Risk Managed Credit Strategies Fund, Anchor Risk Managed Global Strategies Fund, Anchor Risk Managed Equity Strategies Fund

TOPS Managed Risk Growth ETF Portfolio

BTS Tactical Fixed Income Fund

BTS Tactical Fixed Income VIT Fund

Inspire Global Hope ETF, Inspire 100 ETF, Inspire International ESG ETF, Inspire Tactical Balanced ESG ETF, Inspire Small/Mid Cap Impact ETF

General Comment

Main BuyWrite Fund

Toews Hedged U.S. Fund, CMG Tactical Bond Fund

Good Harbor Tactical Select Fund, Newfound Risk Managed U.S. Growth Fund

Navigator Tactical U.S. Allocation Fund, Navigator Tactical Fixed Income Fund, Astor Macro Alternative Fund, Grant Park Multi Alternative Strategies Fund

TOPS Managed Risk Balanced ETF Portfolio, TOPS Managed Risk Moderate Growth ETF Portfolio, TOPS Managed Risk Flex ETF Portfolio, TOPS Managed Risk Growth ETF Portfolio 

Persimmon Long/Short Fund, Newfound Risk Managed U.S. Growth Fund

Anchor Risk Managed Credit Strategies Fund, Anchor Risk Managed Equity Strategies Fund, Anchor Risk Managed Global Strategies Fund

The Fund has always been managed as an unconstrained fund with the flexibility to invest in underlying funds providing exposure to equities, fixed income securities, cash, and commodities/currencies. The Blended Index of 60% MSCI All Country World Index Net (USD) and 40% Bloomberg Barclays Global Aggregate Bond Index better reflects the mandate of the strategy.

The Registrant is aware of other investment companies registered under Form N-1A that use a blended index as the primary benchmark for purposes of disclosing a “broad-based securities market index” under Items 4 and 27 of Form N-1A. The blended index disclosed in the annual report, in the judgment of the investment adviser to this Fund, is more reflective of the market for the principal investments of this Fund compared to a less comparable singular index. The Registrant also notes that its Board of Trustees is comfortable with the use of this blended index as an appropriate benchmark for evaluating this Fund’s performance.

The Registrant is not aware of any written interpretive guidance from the Commission or its Staff stating that a blended index cannot represent an “appropriate broad-based securities market index” as that term is used in Form N-1A. The Registrant also believes its approach is consistent with the principles behind guidance from the Staff regarding the definition and purpose of an “appropriate broad-based securities market index.”

Form N-1A defines “appropriate broad-based securities market index” to mean an index “that is administered by an organization that is not an affiliated person of the Fund, its investment adviser, or principal underwriter, unless the index is widely recognized and used.” The SEC has stated that “[t]he purpose of including return information for a broad-based securities market index was to provide investors with a basis for evaluating a fund’s performance and risks relative to the market.” [Registration Form Used by Open-End Management Investment Companies, SEC Release No. IC-23064 (Mar. 13, 1998).] The Commission has also previously stated that a broad-based index provides investors with a performance indicator of the overall applicable stock or bond markets, as appropriate, and that an index would not be considered to be broad-based if it is composed of securities of firms in a particular industry or group of related industries. The Registrant respectfully notes that the Fund’s blended primary benchmark index reflects the markets in which this Fund principally invests, and is not limited to any sector or other concentrated segment of a securities market. In fact, the blend used is the only practical way to provide a broad comparison for the equity and fixed-income markets in which this Fund invests.

The Registrant believes that the use of a blended primary benchmark index complies with the requirements of Form N-1A and the SEC guidance cited above. As the Staff is aware, funds are increasingly using diverse investment strategies which at times have multiple distinct components and asset classes (e.g., a mix of equity securities, fixed-income securities, cash  and alternative strategies) with various weightings. As a result, it is often the case that the performance of a fund’s strategy may have a higher degree of correlation with a blended index than a more commonly used broad-based index such as the S&P 500 Index. In this regard, the Registrant believes that a blended primary benchmark index, consisting of component indexes that are intended to represent similar risk and investment attributes of the range of the Fund’s holdings, provides investors with a more useful basis for evaluating the applicable Fund’s performance and risks relative to the markets in which the Fund invests, consistent with the SEC’s stated purpose of including return information for a broad-based securities market index.

The Registrant also believes that a blended index would be sufficiently “broad-based” if the index, when considered as a whole, is sufficiently representative of a broad segment of the securities market such that it is “not composed of securities of firms in a particular industry or group of related industries.” The Registrant believes that the Fund’s blended index is sufficiently “broad-based” in part because the component indexes of the blended index are themselves “broad-based securities market indexes.”

In addition, the Registrant emphasizes that, consistent with the SEC’s guidance that funds should have “a significant degree of flexibility to select an index that it believes best reflects the markets in which the fund invests,” funds should be given considerable deference in determining whether a blended benchmark index is an “appropriate broad-based securities market index.”

Beech Hill Total Return Fund

Newfound Risk Managed U.S. Growth Fund