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Northwestern Mutual Series Fund, Inc.

720 East Wisconsin Avenue

Milwaukee, Wisconsin 53202-4797

April 24, 2020

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 No.'s 2-89971; 811-3990

EDGAR CIK No. 0000742212

Ladies and Gentlemen:

On February 14, 2020, the Registrant filed with the Securities and Exchange Commission ("SEC") Post-Effective Amendment No. 77 to the Registrant's registration statement on Form N-1A (the "Registration Statement") under Rule 485(a)(1) of the Securities Act of 1933, as amended (the "Securities Act"), which filing was also submitted as Post-Effective Amendment No. 78 to the Registrant's Registration Statement under the Investment Company Act of 1940, as amended (the "1940 Act"). The Registration Statement includes the offering documents for the Registrant's currently effective 27 series (each, a "Portfolio" and together, the "Portfolios").

The primary purpose of this filing is to respond to oral comments received on March 26, 2020 from Ms. Yoon Y. Choo of the SEC staff (the "Staff") on Post-Effective Amendment No. 77/78.

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.

1)Comment: The Staff notes that a fee waiver must be in effect for at least one year from the effective date of the Registration Statement in order to be reflected in the Fees and Expenses table. Please update any footnote accompanying the Fees and Expenses tables for each of the Portfolios that contains fee waiver information and confirm that any such fee waiver shall be in place for no less than one year. This comment relates to all Portfolios, as appropriate.

Response: Information regarding fee waivers shown in the Portfolios' respective Fees and Expenses tables will reflect fee waiver agreements that are in effect on May 1, 2020 (the effective date of the Registration Statement) and that will remain in effect through at least April 30, 2021. Accordingly, the Registrant confirms that each fee waiver agreement referenced in the Portfolios' respective Fees and Expenses tables shall be in place for no less than one year.

2)Comment: With respect to the Example which accompanies the Expense table for each of the Portfolios, the Staff has requested that the second sentence be revised (as reflected by underline) to provide as follows: "The Example assumes that you invest $10,000 in the Portfolio for the time periods indicated and then redeem or hold all of your shares at the end of those periods."

Response: The Registrant has revised the sentence accordingly for each of the Portfolios.

3)Comment: With respect to any of the Portfolios where the Registrant has identified a Sector Concentration Risk as a Principal Risk, and the investments of the Portfolio in question in a particular sector are deemed significant by Registrant, please identify the sector within the Principal Investment Strategies section, and describe the specific risks associated with significant investment in that sector within the Sector Concentration Risk item. Staff advises this comment applies across all Portfolios.

Response: The Registrant confirms supplementally that it is not a principal investment strategy or other investment policy for any of the Portfolios to invest in a particular sector or sectors. However, the Registrant has determined that the investment selection process employed by certain Portfolios could at times result in the Portfolio having a relatively high percentage of its assets in a particular sector or sectors. A Portfolio may become heavily-weighted in a sector or sectors from time to time as a result of where investment opportunities exist. In addition, a Portfolio that structures its sector weights around the Portfolio's primary benchmark index may have a high percentage of its assets in the sector or sectors that are heavily-weighted within the benchmark at any given time. In order to avoid potential confusion with respect to the use of the term "concentration," Registrant has determined to change the titling of the "Sector Concentration Risk" appearing in the summaries, and discussed in the statutory prospectus, to "Sector Focus Risk."

Registrant has provided additional detailed information with respect to Sector Focus in the statutory prospectus, including disclosure addressing the risks associated with significant investment in the following sectors: information technology, financials, healthcare and industrials. These specific sectors represent the sectors that may, from time to time, exhibit a significant level of investment in the Portfolios, based upon benchmark index sector weightings or a sub-adviser's current assessment of investment opportunities. In addition, the Registrant notes that information on sector allocation and holdings is disclosed in its annual and semi-annual reports to shareholders as of the end of the periods covered by those reports.

4)Comment: Staff notes that significant market events have occurred recently related to the COVID-19 coronavirus. Staff requests Registrant to consider whether, based upon how the coronavirus is affecting both debt and equity markets, the Principal Risk disclosures for each of the Portfolios is adequate. If Registrant believes that no additional disclosure is warranted, please explain supplementally why not.

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Response: Registrant concurs that COVID-19 has had a significant impact on global economies and the financial and securities markets. Registrant has set forth modified and enhanced disclosure addressing the COVID-19 pandemic in its statutory prospectus in a Rule 497 Supplemental Filing made on March 27, 2020. This supplemental filing includes disclosure addressing the coronavirus, its impact on economies and markets, governmental fiscal and monetary policy responses, and the risks related to the foregoing that may be posed to the Fund and its Portfolios. Registrant has also modified the "Market Risk" disclosure, which appears as a principal risk in the summary section for all of the Portfolios, to read as follows:

"Market Risk – The risk that the market price of securities owned by the Portfolio may go up or down, sometimes rapidly or unpredictably. The value of a security may decline due to changes in general market conditions, economic trends or events that are not specifically related to the issuer of the security, or factors that affect a particular issuer or issuers, exchange, country, group of countries, region, market, industry, group of industries, sector or asset class. Global economies and financial markets are increasingly interconnected, which magnifies the potential that conditions in one country or region might adversely impact issuers in, or foreign exchange rates with, a different country or region. Geopolitical and other events, including war, terrorism, economic uncertainty, trade disputes, public health crises (such as epidemics and pandemics), and related events have led, and in the future may lead, to increased market volatility, which may disrupt US and world economies and markets and may have significant adverse direct or indirect effects on the Portfolio and its investments. Such events include the recent pandemic spread of the novel coronavirus known as COVID-19, the duration and full effects of which are still uncertain."

5)Comment: Staff notes that Registrant presently sets forth the Principal Risks for each of the Portfolios in alphabetized order. Staff requests that Registrant revise the ordering of

Principal Risks to prioritize those most likely to affect the particular Portfolio's net assets, yield and total return, in accordance with SEC Staff Guidance set forth in ADI 2019-08.

Response: The Registrant recognizes the SEC's Guidance as set forth in ADI 2019-08, but respectfully declines to change the order in which it discloses its Principal Risks for the Portfolios at this time. Registrant believes that the sections of the Fund's prospectus disclosing principal risks comply with Form N-1A requirements. In addition, as the principal risks are currently clearly listed in alphabetical order, we believe that investors would be aware of that fact and thus would not make any wrongful assumptions regarding the importance of the risk factors based on their current order. Further, as all of the risks listed are risks that we have determined to be principal, we think it would be inappropriate to attempt to emphasize the importance of some risks over others by attempting to change the order of the principal risks based on the magnitude of each risk. The magnitude of a principal risk may increase or decrease over time due to changing market conditions. As such, the order of magnitude may fluctuate during the time period that the Fund's

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Prospectus is effective, potentially rendering the order chosen as of the initial effective date of the Prospectus, inaccurate. Finally, absent some clear standard in Form N-1A as to how to determine the importance of various principal risks, we are concerned that performing this exercise could lead to wide discrepancies across Portfolios based on the perspective of the multiple sub-advisory firms, and among various similar funds throughout the industry, which could ultimately lead to investor confusion when comparing funds, evaluating risks, and attempting to make an investment decision.

6)Comment: The Staff notes that the Portfolio Management section of the Summary Prospectuses should contain information sufficient to determine the length of service of any named portfolio manager, consistent with the requirements of Item 5 (b) of Form N- 1A. Staff indicates that information regarding initial dates of service of a portfolio manager should include the year and month that the manager's service commenced.

Response: Registrant has reviewed the Form N-1A requirements set forth in Item 5(b) related to portfolio manager information and believes it is currently complying with the explicit requirements as set forth in that Item. As a matter of practice, the Registrant will specify the initial service commencement month for a new portfolio manager when the manager has served less than one year. Once the manager has served for at least a year in the capacity of portfolio manager, Registrant then reverts to identifying the year in which the manager's service commenced. We believe this approach is consistent with industry practice and in compliance with the requirements of the Form N-1A.

7)Comment: With respect to the Index 400, Index 500 and Index 600 Stock Portfolios, the Staff requests an explanation of what is meant by the term "cash equitization" as utilized in the Principal Investment Strategies section for each of the Index Portfolios.

Response: Registrant has modified the disclosure in the Principal Investment Strategies section for each of the Index Portfolios in response to the Staff's request. Registrant has added the following disclosure:

"Cash equitization as employed by the Portfolio is a strategy pursuant to which the Portfolio will acquire certain derivative instruments, such as equity index futures, whereby the futures will be utilized to replicate index returns and enable the Portfolio to be fully invested, while still maintaining cash balances as needed by the Portfolio. This strategy works to limit the extent to which uninvested cash will lead to return dispersion from the targeted index."

8)Comment: Staff has made the following comments with respect to the Index Portfolios:

(a)Comment: Each of the Index Portfolios has identified an "Index Concentration Risk" in the Principal Risk section of the summaries. A portion of the disclosure related to "Index Concentration Risk" provides: "Since the Portfolio implements a full replication strategy with respect to the index which it tracks, to the extent the index may be

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concentrated in the securities of issuers in a particular market, industry, group of industries, sector or asset class, the Portfolio may be similarly concentrated." Please add the foregoing language to the Principal Investment Strategies section in the summary prospectuses for the Index Portfolios, as applicable.

Response: Registrant has determined to remove the "Index Concentration Risk" as a separately stated risk for the Index Portfolios. Registrant has modified the existing "Indexing Strategy Risk" that is included as a principal risk for each of the Index Portfolios so that it reads as follows:

"Indexing Strategy Risk – A Portfolio may not perform as well as the index it attempts to match due to the Portfolio's expenses, changes in securities markets, changes in the composition of the underlying index and the timing of purchases and redemptions of Portfolio shares. A Portfolio using a passive management strategy is not "actively" managed, and therefore does not engage in shifting portfolio assets to take advantage of market opportunity, and does not attempt to manage market volatility, use defensive strategies or reduce the effects of any long-term periods of poor stock performance. In addition, changes in the value of a derivative used to replicate an index may not correlate as intended with the underlying index. Since the Portfolio implements a full replication strategy with respect to the index which it tracks, to the extent the index has a significant allocation to an industry or group of industries, a particular sector, or to a single issuer or small number of issuers, the Portfolio will exhibit a significant investment level in that industry, group of industries, sector, issuer or small number of issuers. Portfolio performance may be adversely affected by a significant investment in an industry, group of industries, sector, issuer or small number of issuers, and may be more susceptible to adverse economic, market, political or regulatory developments affecting the industry, group of industries sector or issuer(s) subject to a significant level of investment."

Registrant has made conforming changes (reflecting the modifications outlined above) with respect to the disclosures in the statutory prospectus related to "Indexed Investing" in the section titled, "More About Principal Investment Strategies and Risks."

Registrant confirms that it is not a principal investment strategy or other investment policy for any of the Index Portfolios to invest in a particular industry, group of industries, sector or issuer or small group of issuers. As described in the principal investment strategies section for each of the Index Portfolios, the Portfolios apply a "passive management" approach with the intent of fully replicating the holdings of its target index. While a significant level of investment in a particular industry or group of industries, a particular sector, or an issuer or small number of issuers may occur as a result of replicating the holdings of the index, such result is the by-product of the index replication and not the result of an affirmative investment strategy. Based upon this, Registrant declines to specifically incorporate a reference to the potential for a significant investment level in an industry, group of industries, sector, issuer or small

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group of issuers in the description of the principal investment strategies for the Index Portfolios.

(b)Comment: Where there exists a concentration in an industry or group of industries for an Index Portfolio, add disclosure language to the Principal Investment Strategies section, and the "Index Concentration Risk" in the Principal Risks section, providing that greater than 25% of the Portfolio's assets are invested in a single industry or group of industries. In addition, where such a concentration occurs for an Index Portfolio, iden