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  Proskauer Rose LLP   Eleven Times Square   New York, NY 10036-8299

April 1, 2021

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attention: Deborah O’Neal

    Re:       Lazard Retirement Series, Inc.

    Post-Effective Amendment No. 87 to Registration Statement on Form N-1A

    (Registration Nos.:  333-22309; 811-08071)

To Whom It May Concern:

On behalf of the above-referenced fund
(the “Fund”), on or about April 9, 2021 we plan to file with the Securities and Exchange Commission (the “Commission”)
under the Securities Act of 1933, as amended, and the Investment Company Act of 1940, as amended (the “1940 Act”), Post-Effective
Amendment No. 87 (the “Amendment”) to the Fund’s Registration Statement on Form N-1A (the “Registration Statement”).
The Amendment relates to Post-Effective Amendment No. 86 (“Amendment No. 86”) to the Registration Statement, filed on
January 29, 2021, which was filed: (i) in order to add a new series, Lazard Retirement US Sustainable Equity Portfolio (the “New
Portfolio”), to the Fund; (ii) to reflect certain changes to the investment strategy of Lazard Retirement Emerging Markets
Equity Blend Portfolio (to be known as Lazard Retirement Emerging Markets Strategic Equity Portfolio); and (iii) to reflect certain
previously-effective changes to the investment strategy of Lazard Retirement Real Assets Portfolio (formerly known as Lazard Retirement
Real Assets and Pricing Opportunities Portfolio).

The Amendment will respond to comments
of the staff of the Commission (the “Staff”) on the prospectus included in Amendment No. 86 that were provided to the
undersigned and Devin Kasinki of this office by Deborah O’Neal of the Staff via telephone on March 9, 2021.

For the convenience of the Staff, and for
completeness purposes, the Staff’s comments have been restated below in their entirety, and the response is set out immediately
following each comment. We have considered comments made by the Staff with respect to one section of the Registration Statement
as applicable to similar disclosure elsewhere in the Registration Statement. Capitalized terms used but not defined herein have
the meanings assigned to them in the Amendment.

Summary Section—Fees and Expenses

 1. Staff Comment: Please provide the Staff with the completed fee table and expense examples
at least one week before the effective date of the Amendment.

Response: The completed
fee table and expense examples are attached to this letter as Exhibit A.

 2. Staff Comment: Please confirm whether, in connection with the fee waiver and expense limitation
arrangement in place between the Investment Manager and the Fund on behalf of the Portfolios (the “Expense Limitation Agreement”),
the Investment Manager retains a right to seek reimbursement from the Portfolios for amounts waived or reimbursed by the Investment
Manager pursuant to the Expense Limitation Agreement. If the Investment Manager retains such a right, please disclose the terms
and conditions of this right in footnotes to the fee table.

Response: The Expense
Limitation Agreement contains no provision for recoupment of fee waivers or expense reimbursements, and the Investment Manager
has advised us that it will not seek recoupment from a Portfolio for any fee waivers and expense reimbursements pursuant to the
Expense Limitation Agreement.

Beijing | Boca Raton | Boston | Chicago
| Hong Kong | London | Los Angeles | New Orleans | New York | Paris | São Paulo | Washington, DC

Summary Section—Principal Investment
Strategies

 3. Staff Comment: The second paragraph under “Principal Investment Strategies” for
the New Portfolio states:

The Investment
Manager’s process first identifies companies within the investable universe, which are companies that the Investment Manager believes
are capable of (1) sustaining high financial productivity (i.e., the return a company generates) for periods
in excess of market expectations, or (2) capable of improving financial productivity to a greater extent or more expeditiously
than the market expects (i.e., are undervalued) and which exhibit good expectations for future cash flows and profitability.
Next, the Investment Manager reduces the investable universe using fundamental analysis and research on the companies identified.

(emphasis added). Please consider
revising the disclosure to clarify the intended meaning “sustaining” in contrast to the use of “Sustainable”
in the New Portfolio’s name and investable universe of “Sustainable Companies.”

Response: In the Amendment,
the second paragraph under “Principal Investment Strategies” will be revised as follows:

The
Investment Manager’s process first identifies companies within the investable universe, which are companies that the Investment
Manager believes are capable of (1) sustaining generating and maintaining
high financial productivity (i.e., the return a company generates) for periods in excess of market expectations, or (2)
capable of improving financial productivity to a greater extent or more expeditiously than the market expects (i.e., are
undervalued) and which exhibit good expectations for future cash flows and profitability. Next, the Investment Manager reduces
the investable universe using fundamental analysis and research on the companies identified.

Additional Information

 4. Staff Comment: Form N-1A General Instruction C.3.(c)(iii) states: “[a] prospectus that
contains information about more than one Fund may integrate the information required by any of Items 6 through 8 for all of the
Funds together, provided that the information contained in any Item that is integrated is identical for all Funds covered in the
prospectus.” Please confirm that the tax information for the New Portfolio is identical to the tax information for other funds
which use the same cross reference to the integrated section “Additional Information about the Portfolios.” If such tax
information differs from other Portfolios, please disclose such differences.

Response: Fund management
has confirmed that the tax information for this Portfolio is identical to the information for the other Portfolios.

*     *     *     *     *

We hope the Staff finds that this letter
and the revisions to the prospectus are responsive to the Staff’s comments. Please telephone the undersigned at 212.969.3722 or
Lisa Goldstein at 212.969.3381 if you have any questions.

Very truly yours,

/s/ Robert Spiro

Robert Spiro

    2

EXHIBIT A

Lazard Retirement US Equity Concentrated Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and
hold shares of the Portfolio, a series of Lazard Retirement Series, Inc., but does not reflect the fees or charges imposed by the
separate accounts of certain insurance companies (the “Participating Insurance Companies”) under variable annuity contracts
or variable life insurance policies (the “Policies” and each, a “Policy”). If such fees and charges were
reflected, the figures in the table would be higher.

    Service
Shares
    Investor
Shares

    Annual Portfolio Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    .70%
    .70%

    Distribution and Service (12b-1) Fees
    .25%
    None

    Other Expenses1
    .13%
    .13%

    Total Annual Portfolio Operating Expenses
    1.08%
    .83%

 1 Based on estimated amounts for the current fiscal year.

Example

This Example is intended to help you compare the cost of investing in the Portfolio
with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Portfolio for the time periods
indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes that your investment
has a 5% return each year and that the Portfolio’s operating expenses remain the same. The Example does not reflect fees
and expenses imposed by the Participating Insurance Companies under the Policies; if they were reflected, the figures in the Example
would be higher. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

    1 Year

    3 Years

    Service Shares
    $ 110

    $ 343

    Investor Shares
    $ 85

    $ 265

Lazard Retirement US Sustainable Equity Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and
hold shares of the Portfolio, a series of Lazard Retirement Series, Inc. (the “Fund”), but does not reflect the fees
or charges imposed by the separate accounts of certain insurance companies (the “Participating Insurance Companies”)
under variable annuity contracts or variable life insurance policies (the “Policies” and each, a “Policy”).
If such fees and charges were reflected, the figures in the table would be higher.

    Service
Shares
    Investor
Shares

    Annual Portfolio Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    .60%
    .60%

    Distribution and Service (12b-1) Fees
    .25%
    None

    Other Expenses1
    .20%
    .20%

    Total Annual Portfolio Operating Expenses
    1.05%
    .80%

    Fee Waiver and/or Expense Reimbursement2
    .05%
    .05%

    Total Annual Portfolio Operating Expenses After Fee Waiver and/or Expense Reimbursement
    1.00%
    .75%

 1 Based on estimated amounts for the current fiscal year.

 2 Reflects a contractual agreement by Lazard Asset Management LLC (the ”Investment Manager”) to waive its fee and,
if necessary, reimburse the Portfolio until June 30, 2022, to the extent Total Annual Portfolio Operating Expenses exceed 1.00%
and .75% of the average daily net assets of the Portfolio’s Service Shares and Investor Shares, respectively, exclusive of
taxes, brokerage, interest on borrowings, fees and expenses of “Acquired Funds,” fees and expenses related to filing
foreign tax reclaims and extraordinary expenses. This expense limitation agreement can only be amended by agreement of the Fund,
upon approval by the Fund’s Board of Directors, and the Investment Manager to lower the net amount shown and will terminate
automatically in the event of termination of the Management Agreement between the Investment Manager and the Fund, on behalf of
the Portfolio.

Example

This Example is intended to help you compare the cost of investing in the Portfolio
with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Portfolio for the time periods
indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes that your investment
has a 5% return each year and that the Portfolio’s operating expenses remain the same, giving effect to the expense limitation
agreement described above. The Example does not reflect fees and expenses imposed by the Participating Insurance Companies under
the Policies; if they were reflected, the figures in the Example would be higher. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year
    3 Years

    Service Shares
    $ 102
    $ 318

    Investor Shares
    $ 77
    $ 240

Lazard Retirement US Small-Mid Cap Equity Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and
hold shares of the Portfolio, a series of Lazard Retirement Series, Inc. (the “Fund”), but does not reflect the fees
or charges imposed by the separate accounts of certain insurance companies (the “Participating Insurance Companies”)
under variable annuity contracts or variable life insurance policies (the “Policies” and each, a “Policy”).
If such fees and charges were reflected, the figures in the table would be higher.

    Service
Shares
    Investor
Shares

    Annual Portfolio Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    .75%
    .75%

    Distribution and Service (12b-1) Fees
    .25%
    None

    Other Expenses
    .33%
    .33%1

    Total Annual Portfolio Operating Expenses
    1.33%
    1.08%

    Fee Waiver and/or Expense Reimbursement2
    .18%
    .08%

    Total Annual Portfolio Operating Expenses After Fee Waiver and/or Expense Reimbursement
    1.15%
    1.00%

 1 Based on estimated amounts for the current fiscal year, using “Other Expenses” for Service Shares from the last
fiscal year.

 2 Reflects a contractual agreement by Lazard Asset Management LLC (the “Investment Manager”) to waive its fee and,
if necessary, reimburse the Portfolio until April 30, 2022, to the extent Total Annual Portfolio Operating Expenses exceed 1.15%
and 1.00% of the average daily net assets of the Portfolio’s Service Shares and Investor Shares, respectively, exclusive
of taxes, brokerage, interest on borrowings, fees and expenses of “Acquired Funds,” fees and expenses related to filing
foreign tax reclaims and extraordinary expenses. This expense limitation agreement can only be amended by agreement of the Fund,
upon approval by the Fund’s Board of Directors, and the Investment Manager to lower the net amount shown and will terminate
automatically in the event of termination of the Management Agreement between the Investment Manager and the Fund, on behalf of
the Portfolio.

Example

This Example is intended to help you compare the cost of investing in the Portfolio
with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Portfolio for the time periods
indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes that your investment
has a 5% return each year and that the Portfolio’s operating expenses remain the same, giving effect to the expense limitation
agreement in year one only. The Example does not reflect fees and expenses imposed by the Participating Insurance Companies under
the Policies; if they were reflected, the figures in the Example would be higher. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 year
    3 years
    5 years
    10 years

    Service Shares
    $ 117
    $ 404
    $ 712
    $ 1,586

    Investor Shares
    $ 102
    $ 336
    $ 588
    $ 1,310

Lazard Retirement International Equity Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and
hold shares of the Portfolio, a series of Lazard Retirement Series, Inc. (the “Fund”), but does not reflect the fees
or charges imposed by the separate accounts of certain insurance companies (the “Participating Insurance Companies”)
under variable annuity contracts or variable life insurance policies (the “Policies” and each, a “Policy”).
If such fees and charges were reflected, the figures in the table would be higher.

    Service
Shares
    Investor
Shares

    Annual Portfolio Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    .75%
    .75%

    Distribution and Service (12b-1) Fees
    .25%
    None

    Other Expenses

    Fees and Expenses Related to Filing Foreign Tax Reclaims
    .07%
    .07%1

    Remainder of Other Expenses
    .20%
    .20%1

    Total Other Expenses
    .27%
    .27%

    Total Annual Portfolio Operating Expenses
    1.27%
    1.02%

    Fee Waiver and/or Expense Reimbursement2
    .10%
    .10%

    Total Annual Portfolio Operating Expenses After Fee Waiver and/or Expense Reimbursement3
    1.17%
    .92%

 1 Based on estimated amounts for the current fiscal year, using the amounts for Service Shares from the last fiscal year.

 2 Reflects a contractual agreement by Lazard Asset Management LLC (the “Investment Manager”) to waive its fee and,
if necessary, reimburse the Portfolio until April 30, 2022, t