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April 23, 2021

VIA EDGAR

The United States Securities

    and Exchange Commission

100 F. Street, NE

Washington, D.C. 20549-8629

Subject:
 Nationwide Life Insurance Company

Post-Effective Amendment No. 1
(File No. 333-229802)

CIK Number: 0000205695

RE:
 SEC
Staff Comments to the Nationwide Defined Protection® Annuity Post-Effective Amendment Filed March 1, 2021 (File No. 333-229802)

Dear Ms. Hahn:

On behalf of Nationwide Life
Insurance Company ("Nationwide"), we submit this response letter regarding our Post-Effective Amendment No. 1 that was filed under the Securities Act of 1933 on March 1, 2021. The responses included here are made
based upon comments received from you during the telephone conference on April 15, 2021.

General Comments

1.
 Please respond to all comments in a correspondence letter filed on EDGAR.

 Response. Agreed.

2.
 Where a change is made to the disclosure in the response to a comment, please make corresponding changes wherever similar disclosure appears elsewhere in the prospectus.

 Response. We have made corresponding changes to the disclosure throughout the prospectus as requested.

3.
 With respect to the BlackRock Select Factor Index, supplementally:

a.
 Please confirm that the index methodology used to calculate the index will be publicly available.

 Response. Nationwide confirms that the index methodology used to calculate the index will be publicly available.

b.
 Please confirm that all components of the index are actively traded.

 Response. Nationwide confirms that all components of the index are actively traded.

c.
 Please confirm that the index will be sponsored and administered by a third party, not an affiliated company of Nationwide.

 Response. Nationwide confirms that the index will be sponsored and administered by a third party, not an affiliated company of Nationwide.

Columbus, Ohio 43215-2220
 Nationwide Financial

Legal Counsel to the Nationwide Insurance
Companies and their Associated Companies

d.
 Please confirm whether the index can be replicated by unaffiliated third parties based on the index methodology.

 Response. Nationwide confirms that the index can be replicated by unaffiliated third parties based on the index methodology.

e.
 Please provide a website address where additional information about the index may be found. The Staff may have further comments based on the information on the website.

 Response. Additional information may be found at http://www.Blackrock.com/selectfactor.

Comments to the Section "Indexes"

4.
 In the fourth full paragraph, beginning "As discussed further below, certain Indexes include volatility control methodologies," add a plain English explanation of "volatility control methodologies." Please consider
moving this information to the risk section.

 Response. We added a plain English explanation of "volatility control methodologies" and moved it to the new section titled "Market Exposures and Investment Risks" created as a
result of Comment 5. The disclosure appears in the description of "Volatility Control Risk."

5.
 The Staff notes that some indexes are not complicated (e.g., the S&P 500 Index), while other indexes are complicated (e.g., the BlackRock Select Factor Index). In order to facilitate investor understanding, please consider:

•
 Adding a summary of each index’s methodologies;

•
 Adding a summary of the indexes’ risks, presented in a manner that reduces repetitive disclosure; and

•
 Moving more detailed information about the indexes to an appendix.

 Response. We have added a section titled "Market Exposures and Investment Risks" under "Indexes" in response to the comment above, and moved all descriptions of the indexes’
investment risks to that new section. The new section does not summarize the indexes’ methodologies, but does provide a table reflecting the indexes’ primary market exposures and investment risks. We have
not moved any information to an appendix, as we believe that the revisions described above will facilitate investor understanding.

Comments to Description of BlackRock Select Factor Index

6.
 Consider adding sub-headings to divide the disclosure by topic (i.e., equity ETFs, fixed income ETFs, allocation and weighting) for greater readability.

 Response. We revised the disclosure accordingly.

7.
 The first sentence of the description references the index’s "dynamic exposure" to its component ETFs. Please add a plain English explanation of "dynamic exposure." Alternatively, revise to indicate that the
meaning of dynamic exposure is described further below.

 Response. We revised the disclosure accordingly.

8.
 Please clarify, if accurate, that the index tracks the performance of certain underlying equity and fixed income ETFs, and whether the term "dynamic" relates to the weighting of the ETFs, the components of the
index, or the portfolio holdings of the ETFs.

 Response. We revised the disclosure accordingly.

9.
 Disclose how an investor may obtain information about the current components, weightings, and performance of the index, as well as the components of the underlying ETFs.

 Response. At the beginning of the section titled "Description of the Indexes," we have added disclosure indicating that such information may be obtained for any Index by
contacting an investor’s financial professional or our Service Center. That disclosure also states that similar information about any underlying indexes or ETFs is also available.

Columbus, Ohio 43215-2220
 Nationwide Financial

Legal Counsel to the Nationwide Insurance
Companies and their Associated Companies

10.
 In the paragraph beginning, "The Index uses a rules-based methodology to dynamically adjust the weighting of the ETFs within the Index in response to changing market conditions," the disclosure states that the index
hedges a portion of its exposure to the U.S. equity market. Please clarify how it hedges that exposure.

 Response. We revised the disclosure to clarify how the index hedges its equity market exposure. The disclosure appears under "Information about the Hedged ETF."

11.
 In the paragraph beginning, "Each underlying index includes hypothetical transaction and replication costs that negatively impact the performance of the index," please clarify whether such costs are deducted from
the index, the underlying ETFs, or the indexes that the ETFs seek to track. Please revise to avoid using the term "hypothetical" and to further explain how such costs impact the performance of the index. Please
explain supplementally the purpose for deducting such costs in the calculation of the index.

 Response. We have revised the disclosure accordingly. Please note that the risks associated with these deductions have been moved to the description of "Performance Drag Risk" under
"Market Exposures and Investment Risks," and additional information appears in the index description under the heading "Performance Drag." We have revised the relevant disclosure to describe the rate that is deducted
from the index’s return as part of the index’s methodology. As disclosed in the prospectus, the purpose of such deduction is to more closely align the performance of the index with the performance of a
managed portfolio that takes identical positions as the index. The index is designed to approximate the performance of such a portfolio, and without such deductions, the index could outperform such a portfolio merely
because the index is not subject to fees and costs.

12.
 In the paragraph beginning, "The following is a brief description of the seven equity ETFs." Please revise to "five equity ETFs." In addition, consider adding the iShares Core S&P 500® ETF to that list of equity ETFs, in which case there would be six equity ETFs.

 Response. We revised the disclosure to state there are "five equity ETFs." However, we did not add the iShares Core S&P 500® ETF to the list of equity ETFs because the index hedges rather than tracks that ETF, as described in the prospectus.
However, we have moved the description of the iShares Core S&P 500® ETF to appear under the heading "Underlying ETFs."

13.
 With respect to each underlying ETF, please consider moving the disclosed investment risks to the risk section.

 Response. We moved disclosure about all risks associated with the index to the newly added section titled "Market Exposures and Investment Risks" under "Indexes."

14.
 Each underlying ETF tracks a variation of the MSCI USA Index, please describe the MSCI USA index in greater detail.

 Response. We revised the disclosure to describe the MSCI USA Index in greater detail.

15.
 For each underlying ETF, please clarify how the ETF defines the market capitalization ranges.

 Response. As noted in Comment 14, each underlying ETF seeks to track a variant index of the MSCI USA Index. The MSCI USA Index includes large- and mid-capitalization companies, as
defined by MSCI Inc., the index provider. As such, each underlying ETF invests in companies within the capitalization range defined by MSCI Inc. for the MSCI USA Index. In response to Comment 14, we have provided the
capitalization range of the MSCI USA Index as of a recent date. We believe that provides sufficient information about the capitalization range of the companies in which the ETFs may invest. We believe that providing
the same capitalization ranges for the ETFs and/or variant indexes would be confusing for investors.

16.
 For each underlying ETF, please clarify how the ETF tracks its index (i.e., replication or sampling).

 Response. We revised the disclosure to clarify how each ETF tracks its respective index.

Columbus, Ohio 43215-2220
 Nationwide Financial

Legal Counsel to the Nationwide Insurance
Companies and their Associated Companies

17.
 For each underlying ETF, identify the investment adviser and the index provider. Please describe the relationship between the investment adviser and the index provider. Please disclose any related conflicts of
interest in the risk section.

 Response. We revised the disclosure to identify the investment adviser for each underlying ETF and the index provider for the indexes that the ETFs track. Any conflicts that
Nationwide is aware of have been disclosed in the prospectus.

18.
 For the iShares Edge MSCI USA Momentum Factor ETF, please explain the meaning of "momentum scores."

 Response. We revised the disclosure to explain "momentum scores."

19.
 For the iShares Edge MSCI USA Size Factor ETF, please clarify whether "relatively smaller average market capitalization," "smaller capitalization companies," and "Low Size" are in reference to smaller large- and
mid-capitalization companies, or small-capitalization companies. Consider giving a dollar-range for the relevant market capitalization range.

 Response. We revised the disclosure accordingly. Please note that we did not identify a market capitalization range for that variant index, but did identify a market capitalization
range for the parent index from which stocks are selected, as discussed above.

20.
 For the iShares Edge MSCI Min Vol USA ETF, please clarify the meaning of "lowest absolute volatility."

 Response. We revised the disclosure to clarify the meaning of "lowest absolute volatility."

21.
 With respect to the paragraph beginning, "Each ETF is subject to numerous investment risks," consider disclosing the ETF risks in the risk section.

 Response. We moved disclosure about all risks associated with the index to the newly added section titled "Market Exposures and Investment Risks" under "Indexes."

22.
 Correct the first bullet of ETF risks to read "Each ETF may perform negatively . . . ."

 Response. We updated the disclosure accordingly.

23.
 In the last paragraph, "Use of the BlackRock Select Factor Index in connection with annuity contracts has been exclusively licensed to Nationwide," please state whether there is an expiration date for the exclusive
license. If applicable, disclose the expiration date.

 Response. We updated the disclosure accordingly.

Comments to Description of J.P. Morgan Mozaic IISM Index

24.
 Consider moving disclosure regarding risks associated with the index to the risk factor section.

 Response. We moved disclosure about all risks associated with the index to the newly added section titled "Market Exposures and Investment Risks" under "Indexes."

25.
 With respect to the paragraph beginning, "The prices of government bonds are significantly influenced by the creditworthiness of the governments that issue them," consider starting a new paragraph after the second
sentence. Please also confirm the accuracy of the entire paragraph.

 Response. We revised the paragraph to make it two paragraphs. Additionally, we reviewed both paragraphs and confirm they are accurate. Please note that portions of the
above-referenced disclosure have been moved to "Government Bonds Risk."

26.
 In the paragraph, "The Index may be subject to increased volatility due to the potential use of significant leverage," please disclose the rules governing how the index may use leverage. Please also describe the
risks associated with leverage in the risk section.

 Response. We revised the disclosure accordingly.

Columbus, Ohio 43215-2220
 Nationwide Financial

Legal Counsel to the Nationwide Insurance
Companies and their Associated Companies

27.
 In the paragraph beginning, "The J.P. Morgan Index utilizes a rules-based methodology based on momentum and smoothing volatility," please clarify the meaning of "smoothing volatility."

 Response. We revised the disclosure to avoid using the term "smoothing volatility." We believe the replacement disclosure, along with the disclosure under "Volatility Control Risk,"
is sufficiently clear.

Comments to Description of SG Macro Compass Index

28.
 To the extent applicable, apply all comments under "Comments to Description of BlackRock Select Factor Index" to the description of this index.

 Response. As applicable, we applied the comments to the description of the BlackRock Select Factor Index to the description of the SG Macro Compass Index.

29.
 In the paragraph beginning, "Each underlying index includes hypothetical transaction and replication costs that negatively impact the performance of the index," please clarify whether such costs are deducted from
the index or the underlying indexes. Please revise to avoid using the term "hypothetical" and further explain how such costs impact the performance of the index. Please explain supplementally the purpose for deducting
such costs in the calculation of the index.

 Response. We revised the disclosure accordingly. Please note that the risks associated with these deductions are described in "Performance Drag Risk" under "Market Exposures and
Investment Risks." As disclosed under "Performance Drag Risk," the purpose of such deductions is to more closely align the performance of the index with the performance of a managed portfolio that takes identical
positions as the index. The index is designed to approximate the performance of such a portfolio, and without such deductions, the index could outperform such a portfolio merely because the index is not subject to the
fees and costs. For this index, the "transaction costs" represent a fixed estimate of the costs that would be incurred to buy and sell the index components each time the index rebalances due to changes in weightings
of the index components. The "replication costs" are a fixed estimate of the financing costs that are incurred in holding an investment in the underlying assets of each index component. The costs are deducted from the
index (and one underlying index) on a daily basis and as the index components are re-weighted.

30.
 Please add clear disclosure regarding the number of index components and how often the index rebalances.

 Response. We revised the disclosure accordingly.

31.
 With respect to the list of underlying indexes, please move risk disclosure to the risk