Red Oak Capital Fund III, LLC

625 Kenmoor Avenue SE, Suite 211

Grand Rapids, Michigan 49546

September 17, 2019

VIA EDGAR AND OVERNIGHT MAIL

Stacie Gorman, Esq.

Office of Real Estate and Commodities

Division of Corporation Finance

United States Securities and Exchange Commission

Mail Stop 3233

100 F Street, N.E.,

Washington, DC 20549

Re: 

Red Oak Capital Fund III, LLC (the “Company”)

Amendment No. 3 to Offering Statement on Form 1-A

Filed August 30, 2019

File No. 024-11026

Dear Ms. Gorman:

On behalf of the Company, I respectfully request that the qualification date of the offering statement be accelerated and that the offering statement be declared qualified on September 18, 2019 at 10:00 a.m. ET, or as soon thereafter as is reasonably practicable.

In making this request, the Company acknowledges the following:

●

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing qualified, it does not foreclose the Commission from taking any action with respect to the filing;

●

the action of the Commission or the staff, acting pursuant to delegated authority, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and

●

the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Very truly yours,

/s/ Chip Cummings                             

Chip Cummings