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Ohio National Fund, Inc.

 One Financial Way

Cincinnati, Ohio 45242

Post Office Box 237

 Cincinnati, Ohio 45201-0237

 Telephone: 513-794-6100

 April 23, 2020

Alberto Zapata

 Senior Counsel

 U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review and Accounting Office

100 F Street NE

 Washington, DC
20549

Re:
 Ohio National Fund, Inc. - File Nos. 2-67464, 811-3015

 Dear Mr. Zapata:

On February 7, 2020, Ohio National Fund, Inc. (the “Registrant” or “Fund”), on behalf of its series,
filed Post-Effective Amendment No. 92 (the “Amendment”) to the Registrant’s Registration Statement. On March 25, 2020, you provided oral comments to the Amendment to Angela Fontanini of Ohio National Financial Services.
Redlined changes may be provided in certain portions of this letter to aid in your review. Further, all changes related to the Registrant’s responses to your comments and refining edits will be filed in a Post-Effective Amendment filed pursuant
to Rule 485(b).

 Cover Page

Comment 1.    If the Registrant plans to use the electronic delivery option to deliver shareholder reports going
forward, please add the disclosures required by Item 1(a)(5) of Form N-1A to the Cover Page.

Response.    The Registrant does not plan to use the electronic delivery option to deliver shareholder reports
because the insurance company, as intermediary, will be relying on Rule 30e-3 for delivering shareholder reports.

General

 Comment
2.    We refer you to the Barry Miller letter to the ICI. To the extent that any Portfolio’s principal investment strategies include the use of derivatives, be sure to tailor the disclosure to discuss how the
Portfolio(s) expects to use those derivatives in those strategies rather than provide a generic discussion of derivatives.

Response.    The Registrant believes that its derivatives-related disclosures are consistent with the guidance
provided by the Barry Miller letter.

 Ohio National Life Insurance Company

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 Comment 3.     Explain what the Adviser will be doing in terms of
managing the Portfolios, given that the sub-advisers will be managing the Portfolios and the volatility strategy. Please advise if the Adviser’s role will be administrative or relate to running some other
strategy.

 Response.     The Adviser will provide an oversight and administrative role, including providing
ongoing due diligence oversight of the sub-advisers to monitor their performance and portfolio management. Additionally, the Adviser will provide daily oversight of the derivative instruments in terms of
valuation, usage in relation to the size of the Portfolio and amount of leverage applied. Finally, the Adviser provides the facilities and equipment utilized by Portfolios; supplies business management services to the Fund, including monitoring
expenses accruals and preparing the Portfolios’ financial statements; prepares and files Fund registration statements, proxies, shareholder reports and other regulatory filings; provides financial oversight; and ensures that proxies related to
each Portfolio’s holdings are voted in compliance with policies approved by the Board.

 ON iShares Managed Risk Balanced Portfolio

Comment 4.     The second paragraph of the “Principal Investment Strategies” section on Page 3 states
that the Portfolio may invest in certain derivative instruments. Please add disclosure regarding the purpose of these derivative instruments and if the purpose is purely for volatility and risk management, please disclose as such.

Response.     The Registrant has revised the second paragraph of the “Principal Investment Strategies”
section as follows:

 “The Portfolio may also invest in certain derivative instruments, including equity futures,
fixed income futures and currency futures, and may hold cash and cash equivalents to change the asset allocation exposure in the Portfolio.”

Comment 5.     The third paragraph of the “Principal Investment Strategies” section on Page 3 states that
the Portfolio invests at least 25% of its assets in equity investments and at least 25% of its assets in fixed income investments, but later states in the same paragraph that BlackRock expects to allocate approximately 50% of the Portfolio’s
assets to fixed income investments and to allocate approximately 50% of the Portfolio’s assets to equity investments. It appears that two different sets of percentages are given for the same investments. Please clarify to differentiate between
these different sets of percentages.

 Response.    The difference between these sets of percentages is that the
first set discusses the minimum investments in equity investments and fixed income investments and the second set discusses the expected allocations of the Portfolio’s assets to these investments. The Registrant has revised the language in the
“Principal Investment Strategies” section in the third paragraph as follows:

 “Under normal market
conditions, through investments in the underlying funds and derivatives, the Portfolio invests a minimum of 25% of its assets in equity

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investments and a minimum of 25% of its assets in fixed income investments, and the Portfolio may deviate from these levels in periods of heightened volatility. To achieve the income aspect of
the Portfolio’s investment objective, BlackRock expects to allocate approximately 50% of the Portfolio’s assets to fixed income investments. To achieve the capital appreciation aspect of the Portfolio’s investment objective, BlackRock
expects to allocate approximately 50% of the Portfolio’s assets to equity investments. BlackRock may actively adjust this asset allocation mix in response to prevailing market conditions and in periods of heightened volatility, as described
below.”

 Comment 6.    In the second to last paragraph of the “Principal Investment Strategies”
section on Page 4, there is a reference to “below investment grade” bonds. Please disclose here and elsewhere in the filing that these are also commonly called junk bonds.

Response.     The Registrant has made the requested disclosure here and elsewhere in the filing.

Comment 7.    In the last paragraph of the “Principal Investment Strategies” section on Page 4, consider
adding a heading or other identifier to differentiate, as applicable, the information that relates to the volatility management part of the strategy.

Response.    The Registrant does not believe that a heading or other identifier is necessary, but has revised the
last paragraph of this section as follows:

 “During periods of high volatility, BlackRock will apply a systematic
framework by adjusting the Portfolio’s exposures to attempt to reduce the likelihood of exceeding the maximum expected portfolio volatility. The ON iShares Managed Risk Balanced Portfolio has a volatility cap of 11%. During
periods of increasing expected volatility, the Portfolio may seek to reduce its market exposure by selling shares of underlying funds and/or reducing exposure through equity and/or fixed income futures and other derivatives. During periods of lower
expected volatility, the Portfolio may increase its market exposure by purchasing ETFs and/or increasing exposure through equity and/or fixed income futures and other derivatives.”

Comment 8.    We note that significant market events resulting from the coronavirus have occurred since the
Registration Statement was filed. Please consider whether the Portfolio’s disclosures, including its risk disclosures, should be revised based on how these events are affecting the markets and volatility. If the Fund believes that no additional
disclosures are warranted, please explain supplementally. This comment applies to all five Portfolios.

Response.    The Registrant has made the following revisions:

1)
 The Registrant has added the following sentence to each Market Risk:

“A significant national or international event, natural disaster or widespread health crisis, such as a global pandemic,
could cause substantial market volatility, exchange

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trading suspensions and closures, impact the ability to complete redemptions and affect fund performance.”

2)
 The Registrant has revised our standard Liquidity Risk as follows:

“Liquidity Risk — The Portfolio may not be able to sell some or all of its securities at desired prices or may be
unable to sell the securities at all, particularly during times of market turmoil. Markets may become illiquid when, for instance, there are few, if any, interested buyers or sellers or when dealers are unwilling or unable to make a market for
certain securities. The Portfolio may not be able to sell a restricted or illiquid security at a favorable time or price, thereby decreasing the Portfolio’s overall liquidity. Further, the lack of an established secondary market may make it
more difficult to value illiquid securities. If the Portfolio is forced to sell an illiquid security to meet redemption requests or for other cash needs, the Portfolio may be forced to sell at a loss.”

3)
 The Registrant has added the following enhanced Market Risk disclosure to the “Principal Investment
Strategies and Related Risks” section of the Prospectus:

 “Market Risk

A security’s price may change in response to changes in conditions in securities markets in general. Markets tend to
move in cycles with periods of rising prices and periods of falling prices. They can decline for many reasons, including adverse political or economic developments domestically or abroad, changes in investor psychology, or heavy institutional
selling. In the case of debt securities, changes in the overall level of interest rates affect the security’s price. Different types of stocks sometimes shift into and out of favor with investors. For example, at times the market may not favor
growth-oriented stocks. Instead, it might favor value stocks or not favor stocks at all. If the Portfolio focuses on a particular investment style, its performance will sometimes be better or worse than the performance of funds focusing on other
types of investments.

 A widespread health crisis such as a global pandemic could cause substantial market volatility,
exchange trading suspensions and closures, impact the ability to complete redemptions, and affect fund performance. For example, the novel coronavirus disease (COVID-19) has resulted in significant disruptions
to global business activity. A pandemic can result in travel restrictions, closed international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, prolonged
quarantines, cancellations, supply chain disruptions, and lower consumer demand, as well as general concern and uncertainty. Infectious illness outbreaks can adversely affect the economies of many nations or the entire global economy, individual
issuers and capital markets in ways that cannot necessarily be foreseen. In addition, the impact of infectious illnesses in emerging market countries may be greater due to generally less established healthcare

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systems. Public health crises caused by infectious illness outbreaks may exacerbate other pre-existing political, social and economic risks in certain
countries or globally. The duration of infectious illness outbreaks cannot be determined with certainty.”

 Comment
9.    We note that Interest Rate Risk is listed as a principal risk. Please review this disclosure to determine if it needs to be updated with regard to recent changes in interest rates.

Response.    The Registrant has revised the Interest Rate Risk as follows:

“Interest Rate Risk — Prices of fixed-income securities rise and fall in response to changes in the interest
rates paid by similar securities. Generally, when interest rates rise, prices of fixed-income securities fall. However, market factors, such as the demand for particular fixed-income securities, may cause the price of certain fixed-income securities
to fall while the prices of other securities rise or remain unchanged. Interest rate changes have a greater effect on the price of fixed-income securities with longer maturities. A wide variety of market factors can affect interest rates. Recent and
potential future changes in monetary policy made by central banks and/or their governments are likely to affect the level of interest rates. The Portfolio (directly and indirectly through underlying funds) may be subject to heightened interest rate
risk due to certain changes in monetary policy. Rising interest rates may expose fixed-income markets to increased volatility and may reduce the liquidity of certain investments. These developments also could cause more fluctuation in the net asset
value of the Portfolio and underlying funds or make it more difficult for the Portfolio or underlying funds to accurately value their securities. These developments or others could also cause the Portfolio and the underlying funds to face increased
shareholder redemptions, which could force them to liquidate investments at disadvantageous times or prices, therefore adversely affecting the Portfolio and the underlying funds, as well as the value of your investment.”

Comment 10.    We note that Market Risk is listed as a principal risk. Please consider enhancing the Market Risk
disclosure in light of current market conditions.

 Response.    Please refer to our response to Comment 8.

Comment 11.    We note that the principal risks appear to be in alphabetical order. Please re-order the risks to prioritize the risks that are most likely to adversely affect the Portfolio’s net asset value, yield and total return. This comment applies to all five Portfolios. We refer you to ADI 2019-08 – Improving Principal Risks Disclosure.

 Response.    The
Registrant has considered the staff’s comment. The Registrant notes that Form N-1A does not include a directive or methodology for ordering principal risks. The Registrant respectfully submits
that prioritizing principal risks could involve subjective determinations and could lead to misconceptions regarding the principal risks (either for a particular Portfolio, or relative to other Portfolios). Further, the results of any ranking
may change from time to

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time. The Registrant has not reordered the principal risks at this time, but may consider doing so in the future.

ON iShares Managed Risk Moderate Growth Portfolio

Comment 12.    We make the same comment as Comment 6 above. In the second to last paragraph of the “Principal
Investment Strategies” section, there is a reference to “below investment grade” bonds. Please disclose here and elsewhere in the filing that these are also commonly called junk bonds.

Response.    The Registrant has made the requested disclosure here and elsewhere in the filing.

ON Janus Henderson U.S. Low Volatility Portfolio

Comment 13.    With regard to the “Principal Investment Strategies” section on Page 15, please disclose
the range of securities that the Portfolio expects to hold and indicate if the Portfolio is diversified or non-diversified.

Response.     There is no specific range of securities that the Portfolio expects to hold. The Registrant has
revised the first paragraph of the “Principal Investment Strategies” section as follows:

 “The Portfolio
invests, under normal circumstances, at least 80% of its net assets (plus any borrowings for investment purposes, if any) in U.S. common stocks of companies included in the S&P 500® Index,
utilizing Intech Investment Management LLC’s (“Intech”) mathematical investment process. The Portfolio only invests in common stocks of companies that compose the S&P 500®
Index. A small allocation to cash is maintained for liquidity purposes only. The S&P 500® Index is an unmanaged index of 500 stocks that is generally representative of the performance of
larger companies in the United States. Over time, and under normal market conditions