SecProbe.io

CORRESP
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April 22, 2020

Valerie Lithotomos

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: MML Series Investment Fund (the “Registrant”)

1933 Act File No. 2-39334

1940 Act File No. 811-02224

Comments received for PEA No. 109 filed
on March 2, 2020

MML Series Investment Fund II (the “Registrant”)(collectively,
the “Registrants”)

1933 Act File No. 333-122804

1940 Act File No. 811-21714

Comments received for PEA No. 47 filed on
March 2, 2020

Dear Ms. Lithotomos:

Below is a summary of the comments we received from you on April
14, 2020 regarding the above-mentioned Registrants, together with our responses. We appreciate the time you took to carefully review
these documents and have tried to address your comments. We would greatly appreciate your contacting us at 860-562-2130 or 860-562-2241
as soon as possible if you have any further questions or comments. Thank you.

Comments

 1) Comment: Please confirm that there are no changes to the series included in the filings other than those changes highlighted
in your cover letters.

Response: We confirm that the
changes that necessitated the filing of a 485A POS were highlighted in our cover letters.

 2) Comment: For all “Example” sections, please confirm that the numbers in the “Example” reflect
a fee waiver only for the contractual time period the fee waiver is in effect.

Response: We confirm.

 3) Comment: Significant market events have occurred since this post-effective amendment was filed as a result of the COVID
19 pandemic. Please consider whether the Portfolios’ disclosures, including risk disclosures, should be revised based on
how these events are affecting both debt and equity markets. If the Registrant believes that no additional disclosure is warranted,
please explain supplementally why not.

Response: The Registrants have
updated their risk disclosure. The Registrants have made the following changes to the disclosure in the prospectuses: (underlined
language)

Market Risk. The values of a Fund’s
portfolio securities may decline, at times sharply and unpredictably, as a result of unfavorable broad market developments, which
may affect securities markets generally or particular industries, sectors, or issuers. The values of a Fund’s investments
may decline as a result of a number of such factors, including actual or perceived changes in general economic and market conditions,
industry, political, regulatory, geopolitical and other developments, including the imposition of tariffs or other protectionist
actions, changes in interest rates, currency rates, or other rates of exchange, and changes in economic and competitive industry
conditions. Likewise, terrorism, war, natural and environmental disasters, and epidemics or pandemics may be highly disruptive
to economies and markets. For example, the global pandemic outbreak of the novel coronavirus known as COVID-19 has produced, and
will likely continue to produce, substantial market volatility, severe market dislocations and liquidity constraints in many markets,
and global business disruption, and it may result in future significant adverse effects, such as exchange trading suspensions
and closures, declines in global financial markets, higher default rates, and a substantial economic downturn or recession throughout
the world. Such factors may have a significant adverse effect on a Fund’s performance and have the potential to impair the
ability of a Fund’s investment adviser, subadviser, or other service providers to serve the Fund and could lead to disruptions
that negatively impact the Fund. Different parts of the market and different types of securities can react differently to
these conditions. The possibility that security prices in general will decline over short or even extended periods subjects a
Fund to unpredictable declines in the value of its shares, as well as potentially extended periods of poor performance….”

The Registrants have also added the following disclosure
to the Statements of Additional Information:

Terrorism, War, Natural Disasters, and Epidemics.
Terrorism, war, and related geopolitical events (and their aftermath) have led, and in the future may lead, to increased short-term
market volatility and may have adverse long-term effects on U.S. and world economies and markets generally. Likewise, natural and
environmental disasters, such as, for example, earthquakes, fires, floods, hurricanes, tsunamis, and weather-related phenomena
generally, as well as widespread epidemics, can be highly disruptive to economies and markets, adversely affecting individual companies,
sectors, industries, markets, currencies, interest and inflation rates, credit ratings, investor sentiment, and other factors affecting
the value of the Funds’ investments. For example, the continuing spread of an infectious respiratory illness caused by the
novel strain of coronavirus (known as COVID-19) has caused volatility, severe market dislocations and liquidity constraints in
many markets, and may adversely affect the Funds’ investments and operations. The transmission of COVID-19 and efforts to
contain its spread have resulted in travel restrictions and disruptions, closed international borders, enhanced health screenings
at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, quarantines, event and
service cancellations or interruptions,

and disruptions to business operations (including staff reductions), supply chains, and
consumer activity, as well as general concern and uncertainty that has negatively affected the economic environment.

The COVID-19 virus has negatively affected, and will
likely continue to affect negatively, the global economy, the economies of many countries, and the financial performance of individual
issuers, sectors, industries, asset classes, and markets in significant and unforeseen ways. In addition, actions taken by governmental
and quasi-governmental authorities and regulators throughout the world in response to the COVID-19 outbreak, including significant
fiscal and monetary policy changes, have affected, and likely will continue to affect, the values, volatility, and liquidity of securities
or other assets. The effects of the outbreak in developing or emerging market countries may be greater due to less established
health care systems, financial systems and institutions, and government institutions. The COVID-19 pandemic and its effects
may be short term or may last for an extended period of time, and in either case could result in, among other things, significant
market volatility, exchange trading suspensions and closures, declines in global financial markets, higher default rates, and a
substantial economic downturn or recession. The foregoing could have a significant adverse effect on a Fund’s performance
and have the potential to impair a Fund’s ability to maintain operational standards (such as with respect to satisfying redemption
requests), disrupt the operations of a Fund’s service providers, adversely affect the values and liquidity of a Fund’s
investments, and negatively impact a Fund’s performance and a shareholder’s investment in a Fund. Other infectious
illness outbreaks, epidemics or pandemics that may arise in the future, could adversely affect the economies of many nations or
the entire global economy, the financial performance of individual issuers, borrowers and sectors, and the health of the markets
generally in potentially significant and unforeseen ways.

 4) Comment: Consider adding cyber security risk disclosure.

Response: The Registrants’ prospectuses and
statements of additional information already include disclosure concerning cyber security and technology risk.

 5) Comment: The Principal Investment Strategies for the MML Fundamental Equity Fund state that “[e]quity securities
may include common stocks, preferred stocks, securities convertible into common or preferred stock, rights, and warrants.”
Please advise if there are any additional equity securities the Fund intends to invest in.

Response: If the Fund were to
invest to a significant extent in other types of equity securities, it would consider revising the Fund’s prospectus in accordance
with existing staff guidance.

 6) Comment: Please explain the reasoning for including small and mid-cap company risk disclosure under Principal Risks
for the MML Fundamental Equity Fund.

Response: Although the MML Fundamental Equity Fund
has a principal investment strategy that focuses on large capitalization issuers, it may purchase stocks of companies with any
market capitalization.

 7) Comment: Please explain the reasoning for including small company risk disclosure under Principal Risks for the MML
Mid Cap Growth Fund.

Response: Our Small and Mid-Cap Company Risk
is a standardized risk that includes disclosure regarding both small and mid-cap company risk. This disclosure is used across
all of the funds in our fund complex that invest in either small or mid-cap companies.

 8) Comment: Please complete or update all missing information that is currently in brackets or missing in the Prospectus
and SAI (e.g., performance tables, financial highlights).

Response: We will complete or update
all such bracketed or missing information.

 9) Comment: Please describe how the MML Equity Fund will value derivatives for purposes of its 80% name test.

Response: The Fund does not expect to consider
the values or investment exposures of derivatives for purposes of testing compliance with its 80% name test policy. If the Fund
were to do so in the future, it might consider the specific derivative in question and the investment exposure created by it in
determining how to value the derivative for purposes of the 80% test.

 10) Comment: Please explain the reasoning for including small and mid-cap company risk disclosure under Principal Risks
for the MML Equity Fund.

Response: Although the MML Equity Fund has a principal
investment strategy that focuses on securities of larger size companies, it does not limit its investments to issuers in a particular
capitalization range.

 11) Comment: The Principal Strategies for the MML Inflation-Protected and Income Fund state that the Fund can invest in
exchange-traded funds. Please confirm that a separate line item will be added to the Fund’s Fee Table if its Acquired Fund
Fees and Expenses related to these investments exceed one basis point.

Response: We confirm.

Prospectus Comments related
to changes to the Funds’ principal investment strategies

 12) Comment: Please supplementally inform the staff why the Board of Trustees believes these changes are consistent with
its fiduciary duties and are in the best interests of its shareholders -- who did not vote for these changes. In your response:

 a. Explain in detail what information the Board considered, and how it weighed the information in arriving at its decision.

 b. Explain in detail why the Board concluded that this approach was better for shareholders than other alternatives, such as liquidating
the Fund and starting a new Fund.

 c. Support your explanation of the Board’s deliberations with data. For example, if cost was a consideration, provide
data on the expected cost savings from the proposed changes, as compared with starting a new Fund.

 13) Comment: Please also explain why the Adviser believes these change are consistent with its fiduciary duty to
this Fund.

 14) Comment: Has the Fund notified its shareholders of this planned change? If so, please provide the staff with a
copy of the notice and when and how (e.g., letter, e-mail) it was sent. If not, when will the Fund distribute such
a notice and how?

 15) Comment: What is the composition of the Fund’s shareholder base (e.g., affiliated v. unaffiliated, retail
v. institutional, domestic v. foreign)? What percentage of the Fund’s shares are held by retail investors?

 16) Comment: Please explain in your response why making these changes in a post-effective amendment to the registration
statement of an existing Fund, as opposed to an amendment adding a new series, is consistent with the text and policy of Rule
485(a) under the Securities Act. Explain why you believe this does not provide an unfair competitive advantage over other
registrants, which add new series under Rule 485(a) that go effective within 75 days (as opposed to 60 days).

 17) Comment: Please inform the staff in your response letter what percentage of the Fund’s current portfolio needs
to be re-positioned as a result of these changes.

 18) Comment: Have any shareholders contacted the Fund or intermediaries about this planned transaction? If so, describe
the nature of such communications including whether anyone has expressed displeasure or disagreement with the planned transaction
or threatened legal action.

Response for Comments 12 – 18:

(i) The change to the investment strategy of the MML
Inflation-Protected and Income Fund reflected the recommendation by MML Investment Advisers, LLC (“MML Advisers”) as
to the optimal approach to achieving the investment return contemplated by the Fund’s prospectus. The change from the use
of reverse repurchase agreements to swap transactions was based on a review by the Board of Trustees of the information provided
by MML Advisers regarding the advantages to the Fund of the change. The change related to the means by which the Fund obtains income
in its portfolio, and not to the nature of the Fund’s broad investment exposures. The prospectus disclosure relating to the
Fund makes clear that the Fund’s investment strategies are not fundamental policies and may be changed by the Board of Trustees
without shareholder action. Registrant respectfully submits that a change of this nature is consistent with actions taken by investment
company boards in the ordinary course without shareholder action, and that organization of a new fund in order to accomplish this
change would require undue time and expense and would not be in the best interest of shareholders. The Fund’s prospectus
was supplemented following approval of the change by the Board of Trustees.

(ii) The changes to the investment strategies of the
MML Equity Fund, MML Foreign Fund, MML Fundamental Equity Fund, and MML Mid Cap Growth Fund were implemented in connection with
changes in subadvisers to these Funds. As the staff is aware, and as the prospectus of each Fund discloses, each Fund operates
in accordance with a manager-of-managers exemptive order issued by the Commission. Among the advantages of the manager-of-managers
structure is the role of the Fund’s investment adviser, MML Advisers, in proposing the retention of subadvisers to the Funds,
continuously monitoring and evaluating the subadvisers’ performance, and, where appropriate, recommending changes in subadvisers.
In connection with changes in subadvisers, the description of a Fund’s investment strategy is typically revised to reflect
differences between the specific investment approach of a new subadviser and that of the legacy subadviser. The prospectus disclosure
relating to each Fund makes clear that the Fund’s investment strategies are not fundamental policies and may be changed by
the Board of Trustees without shareholder action.

In connection with any proposal by MML Advisers that
the Board of Trustees consider a change to a Fund’s subadviser, MML Advisers provides a substantial amount of information
to the Fund’s Board of Trustees, including information regarding the investment program and performance of the existing subadviser
and the investment program and performance of the proposed subadviser, and information regarding the subadvisers’ investment
personnel, compliance programs, and operations. MML Advisers makes a specific recommendation regarding the expected benefits to
the Fund and its shareholders of the change in subadviser. It also provides detailed information regarding any change in rel