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Northwestern Mutual Series Fund, Inc.

 Northwestern Mutual Series Fund, Inc.

720 East Wisconsin Avenue

Milwaukee, Wisconsin 53202-4797

April 16, 2025

 VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE:
 Northwestern Mutual Series Fund, Inc. (“Registrant”)

 
 Registration Nos: 2-89971;
811-3990

 
 EDGAR CIK No. 0000742212

Ladies and Gentlemen:

 On
February 13, 2025, the Registrant filed with the Securities and Exchange Commission (“SEC”) Post-Effective Amendment No. 90 to the Registrant’s registration statement on Form N-1A (the
“Registration Statement”) under Rule 485(a)(2) of the Securities Act of 1933, as amended (the “Securities Act”), which filing was also submitted as Amendment No. 91 to the Registrant’s Registration Statement under the
Investment Company Act of 1940, as amended (the “1940 Act”). The Registration Statement was filed to register three new series of the Registrant: Active/Passive Conservative Portfolio (“Conservative Portfolio”), Active/Passive
Aggressive Portfolio (“Aggressive Portfolio”), and Active/Passive All Equity Portfolio (“All Equity Portfolio” and together with the Conservative Portfolio and the Aggressive Portfolio, the “Portfolios” and each, a
“Portfolio”).

 The primary purpose of this filing is to respond to oral comments received on March 6, 2025 from
Ms. Anu Dubey of the SEC staff (the “Staff”) on the Registration Statement.

 The following paragraphs provide the
Registrant’s response to comments received. Each comment has been repeated below in the order received, and the Registrant’s response follows. We hereby confirm that all changes discussed in this letter will be incorporated in the
Registrant’s subsequent post-effective amendment filing under Rule 485(b) (the “485(b) filing”). We also confirm that if disclosure is revised in the 485(b) filing in response to a comment from the Staff, we will make corresponding
changes to the disclosure in other applicable locations within the 485(b) filing.

 Prospectus

1)
 Comment: With respect to the Conservative Portfolio and the Aggressive Portfolio, consider whether
“capital” should be inserted before “appreciation” in each Portfolio’s investment objective. Further, please explain why both investment objectives are “to realize as high a level of total return as is consistent with
reasonable investment risk …” given that “conservative” indicates a lower level or risk than “aggressive.”

Response: The Registrant has revised each Portfolio’s investment objective as follows:

Conservative: The investment objective of the Portfolio is to realize as high a level of total return as is
consistent with reasonable conservative investment risk through income and secondarily through capital
appreciation.

 Aggressive: The investment objective of the Portfolio is to
realize as high a level of total return as is consistent with reasonable aggressive investment risk primarily through capital appreciation and some income.

2)
 Comment: For each Portfolio, please revise the lead-in
paragraph to the “Summary–Fees and Expenses of the Portfolio” section to add “and sell” in accordance with Item 3 of Form N-1A.

Response: The Registrant confirms that the disclosure will be revised as follows:

“The table below describes the fees and expenses that you may pay when you buy, and hold, and sell interests in a separate account that invests in shares of the Portfolio as a result of your purchase of a
variable annuity contract or variable life insurance policy.”

3)
 Comment: For each Portfolio, please provide a completed fee table and expense example for each
Portfolio.

 Response: The Registrant has included the completed fee table and expense example
in Appendix A to this letter.

4)
 Comment: For each Portfolio, in footnote 4 to the fee table, please (i) confirm that the date
of the fee waiver agreement disclosed will be at least one year from the effective date of the Registration Statement; (ii) confirm that the fee waiver agreement will be filed as an exhibit to the Registration Statement; and (iii) disclose
that only the Board can terminate the fee waiver agreement prior to the termination date.

Response: The Registrant confirms that (i) the date disclosed will be at least one year from the effective date
of the Registration Statement; (ii) the fee waiver agreement will be filed as an exhibit to the Registration Statement; (iii) disclosure will be added (as set forth in Appendix A) to note that only the Board can terminate the fee
waiver agreement prior to the termination date.

5)
 Comment: The Staff notes that each Portfolio’s “Principal Investment Strategies”
disclosure does not reflect the “active/passive” terminology in each Portfolio’s name. Please either remove this term or add disclosure to the Principal Investment Strategies to appropriately reflect this name.

Response: The Registrant will add disclosure to the second paragraph of each Portfolio’s “Principal
Investment Strategies” section as follows:

 The Portfolio is one of the Northwestern Mutual Series Fund, Inc.
Allocation Portfolios (Active/Passive Allocation Suite) and operates primarily as a “fund of funds.” The Portfolio invests in a combination of both actively
managed and passive (i.e., index-tracking) underlying Portfolios of Northwestern Mutual Series Fund, Inc. (each, an “Underlying Portfolio”) and exchange-traded funds (“ETFs”) which are not portfolios of Northwestern Mutual Series
Fund, Inc.

6)
 Comment: In each Portfolio’s “Principal Investment Strategies” section, the second
paragraph includes a reference to the risk level indicated in the table. Please either add new disclosure or delete the reference to the risk level indicated.

Response: The Registrant will revise the disclosure as follows:

The Portfolio has a target asset allocation
consistent with the level of risk as indicated in the table below.

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7)
 Comment: With respect to the Conservative Portfolio, the Staff considers the name to be misleading
in light of its planned investment allocation of up to 40% in equity securities and its investment in below investment grade debt as a principal investment strategy. Please either change the name of the Portfolio or revise the Portfolio’s
Principal Investment Strategy as necessary.

 Response: The Registrant will revise the Principal
Investment Strategy as discussed below in order to retain the name “Active/Passive Conservative Portfolio.” The Registrant respectfully notes that the term “conservative” in the Portfolio’s name is not subject to Rule 35d-1 under the 1940 Act (the “Names Rule”) as it is unrelated to the types of investments held by the Portfolio and is not intended to convey an investment focus on a particular characteristic (i.e., any
“feature, quality or attribute”1) shared by the Portfolio’s investments. Rather, “conservative” in this context is intended to convey: (1) the investment objective of
the Portfolio (i.e., realize as high a level of total return as is consistent with conservative investment risk through income and secondarily through capital appreciation) and (2) the overall characteristic of the Portfolio with respect to
investment risk (i.e., the Portfolio presents relatively less risk to the investor than the other Active/Passive Portfolios). The Registrant notes that in the Names Rule Adopting Release, the Staff described certain terms that are not subject to the
Names Rule, noting that in such circumstances the “name communicates information to investors about the overall characteristics of the fund’s portfolio, rather than particular investments in the portfolio . . . .”2 Further, the Registrant believes that the term “conservative” in the Portfolio’s name is not misleading under Section 35(d) of the 1940 Act. The Registrant notes that the term
“conservative” is intended to convey both the investment objective of the Portfolio and the Portfolio’s range of risk relative to the other Active/Passive Portfolios. To make this clear to investors, the Registrant will add the
following disclosure to the Principal Investment Strategy:

 “As a ‘conservative’ Portfolio, the adviser
will allocate the Portfolio’s assets to a combination of underlying funds that is expected to have lower investment risk on a relative basis to the other Portfolios of the Active/Passive Allocation Suite. The Portfolio prioritizes preservation
of capital over capital appreciation and is designed primarily for investors seeking lower volatility while pursuing the income potential of bonds.”

With respect to the Staff’s comment on the investment allocation to equity securities, the Registrant notes that an
allocation of approximately 40% to equities is consistent with peer “conservative allocation” funds. The Registrant also notes supplementally that the Portfolio generally will invest a relatively smaller portion of its assets in small-cap and mid-cap funds as compared to the other Active/Passive Portfolios.

With respect to the Staff’s comment on the investment allocation to high yield bonds, the Registrant notes
supplementally that the Portfolio’s exposure to high yield bonds is through investment in the underlying fixed-income funds which primarily hold investment grade bonds, and accordingly, the Portfolio’s exposure to high yield bonds is not
expected to be significant. To make this clear to investors, the Registrant will revise the relevant disclosure as follows:

“Through its investments in the
fixed income Underlying Portfolios and ETFs, tThe Portfolio may obtain fixed income exposure by investing in one or more fixed income Underlying Portfolios or ETFs, which may hold be exposed to a wide range of fixed income securities with varying durations and maturities., The fixed income securities generally will consist of including investment grade and non-investment grade debt securities, debt of corporate and government issuers, as well as mortgage-backed and asset-backed securities and inflation-indexed debt securities.
, and other fixed income instruments. The

1 Investment Company Names, Release No. IC-35000
(September 20, 2023) (“Names Rule Adopting Release”) at 29.

 2 Id.
at 42.

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Portfolio may also have limited exposure to non-investment grade debt
securities (sometimes referred to as “high yield securities” or “junk bonds”).”

The Registrant supplementally notes the anticipated level of high yield exposure in the Portfolio is consistent with peer
funds categorized as conservative allocation funds which are designed to provide both income and capital appreciation by investing in multiple asset classes, including stocks, bonds and cash, and with the objective to prioritize the preservation of
capital over appreciation.

8)
 Comment: In each Portfolio’s “Principal Investment Strategies” section, in the
footnote to the percentage allocation table, please identify any other exposure that is a principal investment strategy of the Portfolio and add any corresponding risks.

Response: The Registrant confirms supplementally that other exposure includes only REITs and commodities.

9)
 Comment: Each Portfolio’s “Principal Investment Strategies” section includes a
statement that “the Portfolio may invest more than 25% of its assets in one Underlying Portfolio or one ETF.” If a Portfolio will invest more than 25% in another Underlying Portfolio or ETF, please disclose such Portfolio’s or
ETF’s name, its principal investment strategy, and associated principal risks under this Portfolio’s principal risks. Also, please confirm that fund-of-fund
agreements will be filed as an exhibit as necessary.

 Response: The Registrant confirms
supplementally that each of the All Equity Portfolio and the Aggressive Portfolio is not expected to invest more than 25% of its assets in any one Underlying Portfolio or one ETF at launch, although such Portfolios may do so in the future. The
Registrant confirms that it will revise such Portfolios’ disclosures as discussed below with respect to the Conservative Portfolio in the event an investment exceeding 25% of such Portfolios is made.

With respect to the Conservative Portfolio, the Registrant expects that the Portfolio will invest more that 25% of its
assets in an Underlying Portfolio or ETF when investment operations begin; however, the specific Underlying Portfolio or ETF could vary from time to time in light of the investment team’s views on the economic and market outlook. As such, the
Registrant does not believe that disclosing the name of the Underlying Portfolio or ETF in the Prospectus would be helpful to investors as it could lead investors to conclude that such Underlying Portfolio or ETF will be a core holding for the
entire year when in fact it could change over the course of the year. The Registrant does acknowledge, however, that any Underlying Portfolios or ETFs in which the Conservative Portfolio would invest over 25% of its assets would be one that invests
primarily in U.S. fixed-income securities. The Registrant also notes that the list of the Underlying Portfolios or ETFs in which the Conservative Portfolio is invested as of the end of each semi-annual and annual period will be included in the
report on Form N-CSR. As such, the Registrant will add the following to the investment strategy disclosure:

“In connection with the allocation process, the Portfolio may invest more than 25% of its assets in one Underlying
Portfolio or one ETF (specifically, Underlying Portfolios or ETFs that invest primarily in U.S. fixed income securities). A list of the Underlying Portfolios or ETFs in
which the Portfolio is invested as of the most recently completed annual or semi-annual period can be found in the Portfolio’s report on Form
N-CSR.”

 In
addition, the Registrant notes that the principal risks of the Underlying Portfolios or ETFs associated with such investment will be disclosed in the Conservative Portfolio’s “Principal Risks” section of the Prospectus.

Finally, the Registrant notes that
fund-of-fund agreements will be filed as an exhibit to a

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subsequent post-effective amendment as necessary.

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10)
 Comment: With respect to the Conservative Portfolio and the Aggressive Portfolio, consider
reorganizing the fourth paragraph of the “Principal Investment Strategies” section to more clearly define and describe what types of investments are included in the “Equity and Other Exposure,” “Fixed Income or Debt
Exposure” and “Cash Equivalents.” Additionally, please more clearly disclose (i) if the Portfolio will use derivatives as a principal investment strategy to obtain exposure to the “Equity and Other,” “Fixed Income
or Debt,” and/or “Cash Equivalents” categories; (ii) the definition of “Other Exposure” as a principal strategy, including if commodities are included in this category; and (iii) the definitions of “Fixed
Income or Debt Exposure” and “Cash Equivalents” given that the disclosure indicates that a Portfolio may be including ETFs that invest in mortgage-and asset-backed securities as cash
equivalents.

 Response: The Registrant will include in the 485(b) filing the revised disclosure
set forth in Appendix B in response to the Staff’s comments.

11)
 Comment: With respect to the Conservative Portfolio and the Aggressive Portfolio, in the
“Principal Investment Strategies” section, please add a reference to “junk bonds” after the reference to non-investment grade debt securities.

Response: The Registrant will add the requested disclosure as indicated in Appendix B.

12)
 Comment: With respect to the Conservative Portfolio and the Aggressive Portfolio, in the
“Principal Investment Strategies” section, please disclose any other fixed-income instruments that are a part of the principal investment strategies of the Portfolios and disclose the corresponding risk.

Response: The Registrant will revise the disclosure to delete mortgage- and asset-backed securities from the
description of cash equivalents, as the Staff