Mail Stop 3628

                                                            February 8, 2019

Via E-mail
Denise D. Roberts
President
American Express Receivables Financing Corporation III LLC
4315 South 2700 West, Room 1100
Mail Stop 02-01-46
Salt Lake City, Utah 84184

       Re:    American Express Credit Account Master Trust
              American Express Receivables Financing Corporation III LLC
              Registration Statement on Form SF-3
              Filed December 20, 2018
              File Nos. 333-228921 and 333-228921-01

Dear Ms. Roberts:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form SF-3

Form of Prospectus

Pool Asset Review--Underwriting and Authorization Process, page 38

   1. We note your disclosure under "The Pooling and Servicing Agreement
Generally--
      Additions of Accounts" on page 77 of your form of prospectus that
additional accounts
      may be originated using credit, origination or underwriting criteria
different from those
      applied to the initial accounts. Please revise your disclosure as
necessary to describe the
      nature of the review of assets added to the pool (including during the
revolving period)
 Denise D. Roberts
American Express Receivables Financing Corporation III LLC
February 8, 2019
Page 2

       performed by the issuer or sponsor as required by Rule 193 and whether
those assets
       deviate from disclosed underwriting criteria or other criteria. Refer to
Items 1111(a)(7),
       (a)(8) and (g)(7) of Regulation AB. We note also that your form of
prospectus included
       in your currently-effective registration statement included bracketed
disclosure describing
       the nature of the review of assets added to the pool.

Asset Representations Review--Other Matters Relating to the Asset
Representations Reviewer,
page 106

    2. We note that your form of prospectus describes the manner, but not the
amount, in which
       the asset representations reviewer is compensated. Please revise your
disclosure to
       include the amounts payable to the asset representations reviewer
pursuant to the asset
       representations review agreement. Refer to Item 1109(b)(4) of Regulation
AB.

Item 14. Exhibits.

    3. We note that you have not included your asset representations review
agreement in the
       exhibit list. Please revise.

    4. We note that your exhibit list indicates that confidential information
has been omitted
       from Exhibits 4.5.11 and 4.5.12. It appears that these exhibits have
been filed in full
       without redactions. If true, please delete the notations to Exhibits
4.5.11 and 4.5.12 or
       advise.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Denise D. Roberts
American Express Receivables Financing Corporation III LLC
February 8, 2019
Page 3

      You may contact Benjamin Meeks, Special Counsel, at (202) 551-7146 or me
at (202)
551-3313 if you have any questions.


                                                        Sincerely,

                                                        /s/ Rolaine S. Bancroft

                                                        Rolaine S. Bancroft
                                                        Senior Special Counsel
                                                        Office of Structured
Finance


cc:    David A. Kanarek, Esq.
       American Express Company

       Alan M. Knoll, Esq.
       Orrick, Herrington & Sutcliffe LLP