SecProbe.io

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                 The Guardian Life Insurance Company of America
                                7 Hanover Square
                               New York, NY 10004

April 28, 2005

VIA EDGAR

Mr. Barry Entos
Division of Investment Management
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC  20549-0505

            RE: THE PARK AVENUE PORTFOLIO (FILE NOS. 33-23966; 811-5641)

Dear Mr. Entos:

            This letter is in response the comments you relayed to me in our
telephone conversation of April 13, 2005, with respect to the post-effective
amendment to the registration statement of The Park Avenue Portfolio (the
"Portfolio") filed with the Commission on Form N-1A on February 25, 2005 (the
"Amendment"). Each series of the Portfolio is referred to herein as a "Fund."
This letter sets forth each comment and our response.

Prospectus

      1.    Comment: With respect to The Guardian UBS Large Cap Value Fund, we
            believe that companies that currently have the lowest market
            capitalization within the Russell 1000 Value Index do not meet the
            definition of large market capitalization. Please revise the
            definition of what the Fund considers a large cap company.

            Response: Agreed. The applicable disclosure has been revised by
            deleting the second sentence of the first paragraph of the section
            entitled "The Fund's principal investment strategies" and replacing
            it with the following:

                  The Fund defines large market capitalization companies as
                  those companies in the market capitalization range of the
                  Fund's benchmark, the Russell 1000 Value Index. Under normal
                  market conditions, the Fund expects that its median market
                  capitalization will approximate the median market
                  capitalization of the index. As of March 31, 2005, the market
                  capitalization of companies represented in the Russell 1000
                  Value Index ranged between $511 million and $389 billion, and
                  the median market capitalization was $4.5 billion.

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      2.    Comment: In the 80% investment policy of The Guardian UBS Large Cap
            Value Fund, please state that the calculation of the Fund's net
            assets includes borrowings for investment purposes.

            Response: Agreed. The applicable disclosure has been revised as
            requested. In addition, conforming changes have been made to the
            disclosure of The Guardian UBS Small Cap Value Fund. The Guardian
            UBS Large Cap Value Fund and The Guardian UBS Small Cap Value Fund
            are currently the only funds within the Portfolio subject to Rule
            35d-1 under the Investment Company Act of 1940 that are permitted to
            borrow for investment purposes.

      3.    Comment: Please state in the prospectus that information regarding
            each Fund's portfolio holdings is available on the Fund's website.

            Response: Agreed. The following disclosure has been added under the
            section entitled "Risks and Special Investment Techniques - Special
            Investment Techniques - Disclosure of Portfolio Holdings": "A link
            to each Fund's portfolio holdings is accessible on the Funds'
            website at www.guardianinvestor.com."

      4.    Comment: In the section entitled "Risks and Special Investment
            Techniques," please change the heading "Diversification risk" to
            "Asset allocation risk."

            Response: Agreed.

      5.    Comment: As provided in Item 5(a)(2) of Form N-1A, please disclose
            the name, title, length of service and business experience during
            the past 5 years of each portfolio manager who is primarily
            responsible for the day-to-day management of The Guardian UBS Large
            Cap Value Fund and The Guardian UBS Small Cap Value Fund.

            Response: Agreed. The applicable disclosure has been revised, as
            indicated in Exhibit A hereto.

      6.    Comment: Please include the Funds' financial highlights information
            in the Rule 485(b) filing.

            Response: Agreed.

      Statement of Additional Information

      1.    Comment: Please provide the disclosure required in Form N-1A on
            portfolio managers.

            Response: Agreed. The applicable disclosure has been added, as
            indicated in Exhibit B hereto.

      2.    Comment: Please add a fundamental investment restriction stating
            that The Guardian Park Avenue Fund may not issue senior securities.

            Response: Agreed. A fundamental investment restriction has been
            added, stating that the Fund may not "issue any senior securities
            except as permitted by applicable law."

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                                                                               3

      3.    Comment: Please describe the Funds' procedures for monitoring
            compliance with the policies and procedures with respect to
            disclosure of portfolio holdings information, and the procedures and
            for monitoring potential conflicts of interest.

            Response: The applicable disclosure has been revised in response to
            this comment, and is attached hereto as Exhibit C.

      4.    Comment: Please state to whom portfolio holdings information is
            selectively disclosed, the frequency of the time lag for disclosure
            and the restrictions on the use of the holdings information.

            Response: The applicable disclosure has been revised in response to
            this comment. Please see Exhibit C.

      5.    Comment: Please disclose who may specifically authorize the
            disclosure of Fund portfolio holdings information.

            Response: The applicable disclosure has been revised in response to
            this comment. Please see Exhibit C.

      6.    Comment: In the discussion of board approval of the continuation of
            the Funds' investment advisory contracts, please state the factors
            the board considered and how the investment adviser met each of
            those factors.

            Response: The applicable disclosure has been revised in response to
            this comment, and is attached hereto as Exhibit D.

      7.    Comment: Please state how investors may obtain a copy of the Funds'
            proxy voting records.

            Response: Agreed. The following disclosure has been added under the
            section entitled "Investment Advisers and Distributor - Proxy Voting
            Policies and Procedures":

                  Information regarding how each Fund voted proxies relating to
                  the Fund's portfolio securities during the 12-month period
                  ended June 30, 2004 is available without charge upon request
                  on the Funds' website, www.guardianinvestor.com or the
                  Securities and Exchange Commission's website, www.sec.gov.

      8.    Comment: Please state that the Trustees of the Portfolio serve until
            they resign, die or are removed from office.

            Response: The requested disclosure is included under the heading
            "Shareholder Rights" as follows:

                  Each trustee serves until the earlier of: (1) the next meeting
                  of shareholders, if any, called for the purpose of electing
                  trustees and until the election and qualification of his or
                  her successor; or (2) such trustee's death, resignation,
                  retirement or removal by a two-thirds vote

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                                                                               4

                  of the trustees or by a majority vote of the outstanding
                  shares of the Portfolio.

Part C

      Comment: Please file the Portfolio's amended Code of Ethics as an exhibit
      to the registration statement filed under Rule 485(b).

      Response: As indicated in Part C of the Portfolio's registration statement
      filing under Rule 485(a) on February 25, 2005, the Portfolio's revised
      Code of Ethics will be filed by amendment.

Representations

      The Portfolio acknowledges that SEC staff comments or changes to the
disclosure in the registration statement reviewed by the staff do not foreclose
the Commission from taking any action with respect to the registration
statement. In addition, the Portfolio acknowledges that it is responsible for
the adequacy and accuracy of the disclosure in the registration statement. The
Portfolio further acknowledges that it may not assert staff comments as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

                                    * * * * *

      Please do not hesitate to contact me at (212) 598-1297 if you have further
questions or comments, or if you require further information.

Sincerely,

Kathleen M. Moynihan
Assistant Counsel

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                                    EXHIBITS

Exhibit A

UBS LARGE CAP VALUE FUND AND UBS SMALL CAP VALUE FUND

Each Fund is managed by an investment management team at UBS Global AM. John
Leonard is the lead portfolio manager for the UBS Large Cap Value Fund. He works
with other members of the Fund's investment management team in managing the
Fund. Each member of the team is allocated a specific portion of the Fund's
portfolio, over which he or she has independent responsibility for research,
security selection, and portfolio construction. The team members also have
access to additional portfolio managers and analysts at UBS Global AM who
specialize in the various sectors and markets in which the Fund invests. Mr.
Leonard, as coordinator, has responsibility for allocating the Fund's portfolio
among the various managers and analysts, occasionally implementing trades on
behalf of analysts on the team and reviewing the overall composition of the
Fund's portfolio to ensure its compliance with its stated investment objective
and strategies. Mr. Leonard is a Managing Director of UBS Global AM, serves as
its Head of North American Equities and Deputy Global Head of Equities, and has
been with the company since 1995.

Wilfred Talbot is the lead portfolio manager for the UBS Small Cap Value Fund.
He and his team of analysts work exclusively on small cap core and small cap
value investing at UBS Global AM. Mr. Talbot oversees the research with respect
to the Fund, conducts research on industries assigned to him, and constructs the
Fund's portfolio. Mr. Talbot is a Managing Director of UBS Global AM and has
been with the company since 1997.

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Exhibit B

PORTFOLIO MANAGERS

As described in the prospectus, each Fund pays to GIS or GBG, as applicable, a
management fee based on a percentage of the Fund's average daily net assets. GIS
pays a portion of its management fee to UBS Global AM, and GBG pays a portion of
its management fee to BG Overseas, for sub-advisory services to certain Funds.
The portfolio managers are generally paid out of the resources, including the
management fees paid by the Fund, of the Fund's adviser or sub-adviser, and are
not paid from any assets of the Funds or any other managed account. In the case
of the Funds managed by GIS, portfolio managers are paid by Guardian Life, with
a portion of the total available compensation pool allocated to Guardian Life
and GIS, respectively, based on each of those company's assets under management.

A Fund's portfolio managers often manage multiple portfolios for multiple
clients. These accounts may include other mutual funds and accounts managed for
insurance companies and other institutions. In the case of UBS Global AM and BG
Overseas, these other accounts may also include assets for high net worth
individuals, pension funds, collective investment trusts, offshore funds, hedge
funds and other types of accounts. For portfolio managers of GIS, a significant
portion of their portfolio management responsibility is managing the assets of
Guardian Life's general account, a pool of mainly fixed income assets that
supports the death benefit, claims and other obligations underlying
Guardian-issued life, health, disability and other insurance policies (the
"Guardian Assets"). The simultaneous management of multiple portfolios
potentially could give rise to conflicts of interest, as discussed herein.

The discussion that follows includes: (i) a description of the compensation
structure applicable to the portfolio managers of GIS, UBS Global AM and BG
Overseas, respectively; (ii) information about each portfolio manager's
investment in the Fund(s) for which the manager has day-to-day responsibility;
(iii) other accounts managed by the portfolio managers; and (iv) a description
of potential conflicts of interest that may arise with respect to a portfolio
manager's management of the Funds.

Compensation Structure

      Guardian Investor Services LLC. The compensation paid to portfolio
managers is comprised of both base salary and incentive compensation. The base
salary is generally a fixed amount based on the individual's experience and
expertise and is reviewed annually. The purpose of the incentive compensation
plan is to provide portfolio managers with incentive awards that are tied
directly to the performance of the mutual funds and portfolios for which they
are responsible. The incentive component can be a significant portion of their
total compensation. For the mutual funds, the incentive compensation rewards
favorable performance of the mutual funds when compared to peer funds and
positive excess return versus appropriate benchmark indices. For the other
portfolios, the incentive compensation rewards favorable performance relative to
customized benchmark indices.

The mutual fund performance criteria are generally tied to both a peer component
and an index component. The peer component is based on the Fund's performance
relative to the appropriate peer group in the universe of mutual funds as
determined by Lipper, Inc., an independent mutual fund rating and ranking
organization.
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For the fiscal year ended December 31, 2004, incentive compensation took into
account one-year performance; going forward, performance will be measured over
rolling one- and three-year periods, with a phase-in period. Generally,
incentive compensation for a portfolio manager is warranted for performance
better than the 60th percentile relative to the Lipper peer group. The index
component is based on whether the Fund's performance exceeds the performance of
its benchmark index (for example, the Park Avenue Fund's performance is measured
against the performance of the S&P 500 Index). The incentive compensation
calculation for a given portfolio manager is based on appropriate weightings
that reflect that manager's roles and responsibilities with respect to
management of the mutual funds and other portfolios. For equity assets,
management of the Funds accounts for substantially all of the calculation; for
fixed income assets, the calculation is divided between management of the
Guardian Assets and the Funds, respectively. Although under normal circumstances
the Guardian Assets substantially exceed those of the Funds, for purposes of the
calculation, management of the Funds accounts for approximately 50% or more of a
manager's inc