SecProbe.io

CORRESP
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MARK KARPE

Assistant Vice President, Counsel

Office: (949) 219-3224

Fax: (949) 219-3706

E-mail:
Mark.Karpe@PacificLife.com

September 27, 2024

VIA EDGAR

Michael A. Rosenberg, Esq.

Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    RE:
    Pacific Select Fund

    File Nos. 033-13954 and 811-05141

Dear
Mr. Rosenberg:

This letter is being provided in response to comments received from
the U.S. Securities and Exchange Commission (“SEC” or the “Commission”) staff (“Staff”) on August 16,
2024, concerning post-effective amendment No. 169 to the registration statement of Pacific Select Fund (“Registrant”)
on Form N-1A (including the Prospectuses (“Prospectus”), Statement of Additional Information (“SAI”) and
Part C), which was filed with the Commission on July 10, 2024 pursuant to Rule 485(a) under the Securities Act of
1933 on behalf of the Bond Plus Portfolio, Large-Cap Plus Bond Alpha Portfolio, QQQ Plus Bond Alpha Portfolio, Small-Cap Plus Bond Alpha
Portfolio and International Equity Plus Bond Alpha Portfolio (each a “Fund” and together the “Funds”).

Revisions discussed below will be applied globally to applicable Funds.
This letter is being provided at least 10 days prior to the effectiveness of the post-effective amendment.

Set forth in the numbered paragraphs below are the Staff’s comments
(in italics) followed by Registrant’s responses.

Prospectus Comments

General Comments (globally applied as applicable)

 1. Comment:
                                            Annual Fund Operating Expenses – Expense Limitation Agreement: Please
                                            disclose that prior to the renewal period of the expense limitation agreement (expense cap),
                                            the investment

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Pacific Select Fund – Response Letter

September 27, 2024

adviser may not terminate this agreement
without approval from the Board of Trustees. Each Fund should also state that the investment adviser may recoup from the Fund amounts
reimbursed in future periods not to exceed three years from the date on which the reimbursement took place provided the recoupment combined
with certain other expenses would be limited to the lesser of (1) the expense cap at the time of reimbursement or (2) the Fund’s
then-current expense cap.

Response:
The cited disclosure only applies to the QQQ Plus Bond Alpha Portfolio and was presented as a footnote to that Fund’s
Annual Fund Operating Expenses table in post-effective amendment No. 169. Registrant therefore respectfully declines to make any
disclosure changes.

 2. Comment:
                                            Principal Investment Strategies – Rule 35d-1: For each Fund’s
                                            80% policy, please revise “assets” to state “net assets plus borrowings
                                            for investment purposes.”

Response:
Consistent with plain English principles, “assets” is used in the Principal Investment Strategies section to avoid
unnecessary technical jargon. Replacing “assets” with “net assets plus borrowings for investment purposes” would
not be meaningful to most readers and moreover, doing so could obfuscate the more important elements of the 80% policy, namely the category
of investments to which the 80% test applies. In addition, Registrant discloses the technical definition in the Non-Fundamental Investment
Restrictions section of the SAI, and disclosure defining assets for Rule 35d-l purposes is included in the General Investment Information
section of the Prospectus.

 3. Comment:
                                            Principal Investment Strategies – Passive Exposure: Given the ability
                                            of Pacific Life Fund Advisors LLC (“PLFA”) to actively manage their portion of
                                            the Fund through various types of swaps as well as seeking incremental alpha through futures,
                                            please explain to the Staff the appropriateness of describing the PLFA-managed portion of
                                            the Fund as seeking passive exposure.

Response:
Registrant has revisited the disclosure and agrees that the reference to passive exposure could be confusing to investors
given PLFA’s active management of the strategy and the disclosure related to that. The term “passive” will be deleted.

 4. Comment:
                                            Principal Investment Strategies – Incremental Alpha: In plain English, please
                                            explain the definition of “incremental alpha”.

Response:
In light of the Staff’s comment, the disclosure will be revised accordingly to provide a plain English definition of
incremental alpha as seeking “to achieve additional gains above the Index by making specific investment decisions for the Fund
as it sees investment opportunities.”

 5. Comment:
                                            Principal Investment Strategies – Junk Securities: Please disclose in the FDS
                                            managed portion of each Fund the extent to which such portion of the Fund may invest in below
                                            investment grade securities, and state that such securities are known as ‘junk bonds.’

Response:
FDS does not currently intend to invest in any debt securities that are rated below investment grade. The disclosure notes
that the FDS portion of each Fund will be invested

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Pacific Select Fund – Response Letter

September 27, 2024

“primarily” in investment
grade debt securities because that portion may also invest in other types of instruments (e.g., repurchase agreements and derivatives)
and not because it may invest in non-investment grade debt.

 6. Comment:
                                            Principal Risks – Swap Agreements Risk: Consider describing in the Principal
                                            Risks section those risks associated with credit default swaps, interest rate swaps and swaptions.

Response:
Registrant has considered the comment but respectfully declines to add the suggested risk disclosures at this time. The primary
swap vehicles expected to be utilized for the Funds are total return swaps, which risks are specifically discussed in the Swap Agreements
Risk in the Fund Summaries section. Risks associated with other types of swaps that may be utilized by the Funds to a lesser extent
are covered under both the Swap Agreements Risk as well as the Derivatives Risk (summary and the more expansive Item 9
statutory). Registrant will endeavor to revisit this topic once the Funds are operational for appropriate changes based upon the actual
use by the Funds of total return swaps as well as other types of swaps.

 7. Comment:
                                            Principal Risks – Restricted Securities Risk: Consider amending disclosure if
                                            Restricted Securities Risk is also applicable to swaps as much as swaps are generally not
                                            registered securities.

Response:
Registrant is not aware of a swap being considered a restricted security that is subject to provisions of Rule 144A other
than the rare case that the swap itself involves a restricted security, which is not the case with the Funds. The Funds intend to enter
into swaps without a view towards distributing or reselling. Registrant respectfully declines to amend the disclosure as it does not
believe Restricted Securities Risk is applicable to the swaps that the Funds plan to principally utilize.

 8. Comment:
                                            Principal Risks – Credit Risk: Please state that debt investments rated Baa/BBB
                                            may have speculative characteristics in that securities rated close to or below investment
                                            grade are considered primarily speculative with respect to the issuer’s ability to
                                            pay interest and repay principal.

Response:
Registrant respectfully disagrees with the Staff’s opinion that that debt investments rated at Baa or BBB by
the Rating Agencies are considered “primarily speculative” as the ratings of Baa/BBB are considered investment grade debt
and thus do not necessarily have more speculative characteristics than any other investment grade debt categories, as compared to debt
investments rated lower than Baa or BBB by the Rating Agencies which are considered non-investment grade debt and thus have more
speculative characteristics than debt rated investment grade (such as Baa/BBB).

 9. Comment:
                                            Performance: Supplementally provide the names of the anticipated broad-based market
                                            index for each Fund.

Response:
The Funds’ broad-based securities market indices for performance comparison purposes are anticipated to be the following:

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Pacific Select Fund – Response Letter

September 27, 2024

    Fund
    Broad-Based
    Market Index

    Bond
    Plus Portfolio
    Bloomberg
    US Aggregate Bond Index

    International
    Equity Plus Bond Alpha Portfolio
    MSCI
    EAFE Index

    Large-Cap
    Plus Bond Alpha Portfolio
    S&P
    500 Index

    QQQ
    Plus Bond Alpha Portfolio
    S&P
    500 Index

    Small-Cap
    Plus Bond Alpha Portfolio
    S&P
    500 Index

Specific Fund Comments

 10. Comment:
                                            Principal Risks – ETF Market Trading Risk (Bond Plus Portfolio only): Based
                                            on the disclosure in the strategy section that indicates the Bond Plus Portfolio’s
                                            exposure to ETFs is through swaps, please explain that the ETF market trading risks are applicable
                                            to ETF exposure through swaps as well as direct exposure.

Response:
The disclosure will be amended accordingly to reflect that this Fund’s exposure to ETFs is only indirect exposure through
swaps.

 11. Comment:
                                            Annual Fund Operating Expenses – Waivers (Large-Cap Plus Bond Alpha Portfolio
                                            only): The management fee is 0.45% for both classes for this Fund. However, after the management
                                            fee waiver, the Total Annual Fund Operating Expenses for Class P shares are 0.43%, which
                                            is less than the management fee. Please explain how that does not constitute impermissible
                                            cross-subsidization of the management fee under Rule 18f-3. Please refer to the SEC
                                            Investment Management Staff’s bulletin issued on February 2, 2023. “Differential
                                            Advisory Fee Waivers” (the “SEC Bulletin”).

Response:
The purpose of an advisory fee waiver is to reduce the fees being charged by a portfolio, resulting in lower costs to its
shareholders. Class I shares and Class P shares for this Fund have an advisory fee (“management fee”) of 0.45%
which is reduced to 0.40% for both share classes due to an advisory fee waiver of 0.05% that is applied uniformly to both share
classes as per Rule 18f-3(b). In compliance with the SEC Bulletin, this Fund does not have a fee waiver that results
in different investment advisory fees for different share classes of the same fund (“differential advisory fee waivers”)
that results in cross-subsidization. Instead, this Fund has different net total annual fund operating expenses between
the two share classes due solely to a difference in the application of a service fee of 20 basis points for Class I shares as compared
to no service fee for Class P shares, as allowable under Rule 18f-3. Both share classes have a 3 basis point expense of Other
Expenses.

The Fund’s advisory fee waivers
are periodically reviewed by Registrant to confirm that there is no inadvertent cross-subsidizations between classes. In addition, the
Fund’s Board approves advisory fee waiver arrangements and Registrant provides updates to such arrangements on at least an annual
basis.

 12. Comment:
                                            Principal Investment Strategies – Comparable Index (Large-Cap Plus Bond Alpha
                                            and Small-Cap Plus Bond Alpha Portfolios only): Please discuss under what circumstances will

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Pacific Select Fund – Response Letter

September 27, 2024

these two
Funds use a comparable index and if shareholders would be notified in advance of such a change.

Response:
The disclosure will be revised accordingly to discuss the circumstances when a Fund will use a comparable index and address
shareholders notification.

 13. Comment:
                                            Principal Investment Strategies – Growth and Value (all Funds except the QQQ
                                            Plus Bond Alpha Portfolio): Please disclose in the Principal Investment Strategies
                                            that these Funds will be invested in both growth and value companies as noted in the Principal
                                            Risks.

Response:
Registrant notes that such disclosure is reflected in the Principal Investment Strategy disclosure of each Fund (other than
the QQQ Plus Bond Alpha Portfolio) regarding the use of total return swaps and/or futures contracts to take positions in the growth or
value segments of U.S. equity markets. As such, no further disclosure is necessary.

 14. Comment:
                                            Principal Investment Strategies – Nasdaq-100 Indices (QQQ Plus Bond Alpha Portfolio
                                            only): Please explain the difference between the Nasdaq-100 Index and the Nasdaq-100 Total
                                            Return Index. Consider removing one of the referenced indices as they are both the same index
                                            with the same components, with the only difference being how performance is measured.

Response:
While it is true that both indices have the same components (namely, the same 100 Nasdaq listed companies), the performance
of each index is measured differently, and the different performance results will be utilized differently as the Fund plans to utilize
different types of derivatives to seek to track the performance of each index separately. Registrant therefore respectfully declines
to make the requested change.

 15. Comment:
                                            Principal Investment Strategies and Risk – Concentration (QQQ Plus Bond Alpha
                                            Portfolio): State that, to the extent that this Fund’s index concentrates in a particular
                                            industry or group of industries, that this Fund will similarly concentrate. State that the
                                            Nasdaq-100 Index is currently concentrated in Technology and include in the risk section
                                            those risks of concentrating generally and specifically the risks associated with any industry
                                            in which this index may concentrate.

Response:
The disclosure will be revised accordingly to clarify that a concentration of the Nasdaq-100 Indices may result in a similar
exposure for the portion of the Fund that uses derivatives to gain exposure to the Nasdaq-100 Indices, with specific reference to the
Technology sec