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CORRESP
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CORRESP

 Stradley Ronon Stevens & Young, LLP

 100 Park Avenue, Suite 2000

 New York, NY 10017

 Telephone 212.812.4124

 Fax 646.682.7180

www.stradley.com

 June 5, 2024

Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Investment Management

 100 F Street, NE

Washington, D.C. 20549

 Attn: Deborah O’Neal

Re:   Northern Institutional Funds (the “Trust”)

     File No. 811-03605

Dear Ms. O’Neal,

On behalf of the Trust, please find below the response to the Staff’s comments provided on May 21, 2024 with regard
to Post-Effective Amendment No. 107 to the Trust’s Registration Statement on Form N-1A (the “Amendment”) related to the Siebert Williams Shank Shares of the Treasury Instruments Portfolio
(the “Portfolio”), which was filed pursuant to paragraph (a)(1) of Rule 485 under the Securities Act of 1933, as amended, on April 12, 2024. Each comment is summarized below, followed by the Trust’s response to the comment.
Capitalized terms not otherwise defined in this letter have the meanings assigned to them in the Amendment.

1.
 Comment. Please provide the completed fee table and cost example for the Portfolio.

 
 Response. The completed fee table and cost example for the Portfolio are provided below:

 
 Fee table:

 Shareholder Fees (fees paid directly from your investment)

 None

 Annual Portfolio Operating Expenses (expenses that you pay each year as

a percentage of the value of your investment)

Siebert Williams 
Shank Shares 

 Management Fees

0.16% 

 Other Expenses(1)

0.06% 

 Transfer Agent Fees

0.02%   

 Service Fees

None    

 Other Operating Expenses

0.04%   

 Total Annual Portfolio Operating Expenses

0.22% 

 Expense
Reimbursement(2)

(0.04)% 

 Total Annual Portfolio Operating Expenses After Expense
Reimbursement

0.18% 

(1)
 “Other Expenses” are based on estimated amounts for the current fiscal year.

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(2)
 Northern Trust Investments, Inc. (“NTI”) has contractually agreed to reimburse a portion of the operating
expenses of the Portfolio so that after such reimbursement the Total Annual Fund Operating Expenses of the Portfolio (excluding (i) acquired fund fees and expenses; (ii) service fees; (iii) the compensation paid to each Independent
Trustee of the Trust; (iv) expenses of third party consultants engaged by the Board of Trustees; (v) membership dues paid to the Investment Company Institute and Mutual Fund Directors Forum; (vi) expenses in connection with the
negotiation and renewal of the revolving credit facility; and (vii) extraordinary expenses and interest) do not exceed 0.18%. This contractual limitation may not be terminated before June 11, 2025, without the approval of the Board of
Trustees.

 
 Cost example:

  1 Year  

  3
Years  

 Siebert Williams Shank Shares

$18

$67

2.
 Comment. Please confirm that there are no recoupment provisions in the Expense Reimbursement
Agreement between the Trust, with respect to the Portfolio, and the Adviser.

 
 Response. The Trust confirms that the Adviser is not entitled to collect on or make a claim for
reimbursed expenses that are the subject of the current Expense Reimbursement Agreement between the Adviser and the Trust, on behalf of the Portfolio, at any time in the future for prior fiscal years.

3.
 Comment. Please confirm that the Portfolio’s expense reimbursement agreement will be in place
for no less than one year from the effective date of the Fund’s registration statement.

 
 Response. The Trust confirms that the Portfolio’s expense reimbursement agreement will be in
place for no less than one year from the effective date of the Fund’s registration statement.

4.
 Comment. Please confirm if the Siebert Williams Shank Shares of the Portfolio have a minimum
subsequent investment. If so, please revise disclosure accordingly.

 
 Response. The Trust confirms that the Siebert Williams Shank Shares of the Portfolio will not have a
minimum subsequent investment.

5.
 Comment. On page 6 of the Amendment, the Trust includes the following disclosure: “A discussion
regarding the Board of Trustees’ basis for its most recent approval of the Portfolio’s Management Agreement will be available in the Portfolio’s first annual or semi-annual report to shareholders following commencement of
operations.” In connection with the SEC’s amendments regarding tailored shareholder reports, please revise such disclosure to reflect that such discussion will be filed on Form N-CSR.

 
 Response. The Trust notes that the adopting release for the amendments related to tailored shareholder
reports states that the SEC intended to eliminate the disclosure requirement cited above:

 We are also
adopting a conforming amendment eliminating Item 10(a)(1)(iii) of amended Form N-1A, which requires funds to include, in the SAI, a statement

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noting that a discussion regarding the basis for the board’s approval of any investment advisory contract is available in the fund’s annual or semi-annual report, as applicable, and
providing the period covered by the relevant report.

 
 See Tailored Shareholder Reports for Mutual Funds and Exchange-Traded Funds; Fee Information in
Investment Company Advertisements, SEC Release Nos. 33-11125; 34-96158; IC-34731, at fn 428 (October 26, 2022).

 
 As discussed during a follow-up call on May 23, 2024, in light
of the discussion in the adopting release, the Trust will remove the statement that “A discussion regarding the Board of Trustees’ basis for its most recent approval of the Portfolio’s Management Agreement will be available in the
Portfolio’s first annual or semi-annual report to shareholders following commencement of operations.”

Please do not hesitate to contact me at (212) 404-0654 if you have any questions or
wish to discuss the responses presented above.

 Very truly yours,

 /s/ Jamie M. Gershkow

  Jamie M. Gershkow

Cc:
  Jose J. Del Real

 
  Kevin O’Rourke

 
  Michael D. Mabry

 
  Joel D. Corriero

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