March 8, 2019

By Hand

Ms. Katherine W. Hsu

Chief, Office of Structured Finance

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E., Mail Stop 3628

Washington, D.C. 20549-3628

Re: American Express Credit Account Master Trust

American Express Receivables Financing Corporation III LLC

Registration Statement on Form SF-3

Filed December 20, 2018

Response to SEC Comment Letter dated February 9, 2019

File Nos. 333-228921 and 333-228921-01                    

Dear Ms. Hsu:

On behalf of American Express Receivables Financing Corporation III LLC (“RFC III”), as depositor (the “Depositor”) to the American Express Credit Account Master Trust (the “Trust” or the “Issuing Entity”), this letter responds to your letter, dated February 9, 2019, providing comments to the Registration Statement on Form SF-3 (the “Registration Statement”) submitted on December 20, 2018 by the Depositor and the Issuing Entity. The Depositor, American Express National Bank (“AENB”), as sponsor (the “Sponsor”), and American Express Travel Related Services Company, Inc., as servicer of the Trust, are collectively referred to herein as “American Express.”

For your convenience, each of your comments has been reproduced below, followed by our response. Enclosed with this letter is Amendment No. 1 to the Registration Statement on Form SF-3 (“Amendment No. 1”), dated March 8, 2019, marked to show all changes to the Registration Statement. All capitalized terms defined in Amendment No. 1 and used in the following responses without definition have the meanings specified in Amendment No. 1. Unless otherwise specified, page numbers used in the responses below refer to pages in the enclosed marked copy of Amendment No. 1.

Ms. Katherine W. Hsu

March 8, 2019

Page 2

Registration Statement on Form SF-3

Form of Prospectus

Pool Asset Review—Underwriting and Authorization Process, page 38

Comment 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) 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.
Response:	American Express confirms that it currently has no expectation of designating to the Trust additional accounts originated using credit, origination or underwriting criteria materially different from those applied to the initial accounts. However, in response to Comment 1, American Express has added the bracketed disclosure from its currently-effective registration statement on page 39.
Asset Representations Review—Other Matters Relating to the Asset Representations Reviewer, page 106
Comment 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.
Response:	American Express confirms that the fees payable to the asset representations reviewer have been, and will continue to be, paid outside of the transaction waterfall directly or indirectly by RFC III, as is disclosed in the Registration Statement and in accordance with the Amended and Restated Asset Representation Review Agreement (the “ARR Agreement”), and that such fees have not been, and will not be, paid from the cash flows from the pool assets or by the Trust. The ARR

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Ms. Katherine W. Hsu

March 8, 2019

Page 3

	Agreement is incorporated by reference into the Registration Statement and, in response to Comment 3 below, American Express has listed the ARR Agreement, previously filed on Form 8-K, as Exhibit 10.1 to the Registration Statement. If the ARR Agreement were to be amended in the future to provide for the payment of the fees payable to the asset representations reviewer out of the transaction waterfall, American Express would file such amendment with the Commission and include disclosure, consistent with market practice, pursuant to Item 1109(b)(4) as well as Item 1113(c), which requires separate tabular disclosure of transaction fees and expenses, but solely to the extent they are “to be paid or payable out of the cash flows from the pool assets.”
Item 14. Exhibits.
Comment 3:	We note that you have not included your asset representations review agreement in the exhibit list. Please revise.
Response:	In response to Comment 3, American Express has listed the Amended and Restated Asset Representations Review Agreement, previously filed on Form 8-K, as Exhibit 10.1 to the Registration Statement.
Comment 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.
Response:	In response to Comment 4, American Express has deleted the notations to Exhibits 4.5.3, 4.5.4, 4.5.5, 4.5.11 and 4.5.12 as such exhibits were filed in full without redactions.

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Ms. Katherine W. Hsu

March 8, 2019

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If you have any questions or comments concerning this response, please do not hesitate to contact me at (212) 506-5077 or my partner, Robert Moyle, at (212) 506-5189.

Sincerely,

/s/ Alan M. Knoll

Alan M. Knoll

Enclosures

cc: Rolaine S. Bancroft, Securities and Exchange Commission

Benjamin Meeks, Securities and Exchange Commission

Laureen E. Seeger, American Express Company

David A. Kanarek, American Express Company

Kerri S. Bernstein, American Express Company

Robert B. Moyle, Orrick, Herrington & Sutcliffe LLP

S. Chris Min, Orrick, Herrington & Sutcliffe LLP

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