April 18, 2017
Valerie Lithotomos
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | MML Series Investment Fund (the “Registrant”) |
1933 Act FileNo. 2-39334 |
1940 Act FileNo. 811-02224 |
Comments received for PEA No. 100 filed on March 2, 2017 |
Dear Ms. Lithotomos:
Below is a summary of the comments I received from you on April 12, 2017 regarding the above-mentioned Registrant, together with our responses. I appreciate the time you took to carefully review these documents and have tried to address your comments. I would greatly appreciate your contacting me at860-562-2241 as soon as possible if you have any further questions or comments. Thank you.
Prospectus
1) | Comment:Given that the MML Global Fund has the word “global” in its name, please expressly describe how the Fund will invest its assets tied economically to a number of countries throughout the world. See Note 42 in Investment Company Act Release No. 24828. |
Response: We previously added the following disclosure in response to this comment from the staff in April 2015: “MFS normally allocates the Fund’s investments across different countries and regions . . .”
2) | Comment: Supplementally confirm for the MML Large Cap Growth Fund that the use of the capitalization range of companies included in the Russell 1000® Growth Index is reflective of the name of the Fund for purposes of its name test. |
Response: We confirm. We note that as of February 28, 2017 the market capitalization range of companies included in the Russell 1000 Growth Index was between $75 million and $719.94 billion.
3) | Comment: Supplementally confirm for the MML Mid Cap Growth Fund that the use of the capitalization range of companies included in either of the S&P MidCap 400® Index or the Russell Midcap® Growth Index is reflective of the name of the Fund for purposes of its name test. |
Response: We confirm. We note that as of February 28, 2017 the market capitalization range of companies included in either of the S&P MidCap 400 Index or the Russell Midcap Growth Index was between $75 million and $59.37 billion.
4) | Comment: Supplementally confirm for the MML Mid Cap Value Fund that the use of the capitalization range of companies included in the Russell 3000® Index, excluding the 100 largest companies, is reflective of the name of the Fund for purposes of its name test. |
Response: We confirm. We note that as of February 28, 2017 the market capitalization range of companies included in the Russell 3000 Index, excluding the 100 largest companies, was between $8 million and $51.43 billion.
Very truly yours,
/s/ Jill Nareau Robert |
Jill Nareau Robert |
Assistant Secretary, MML Series Investment Fund |
Assistant Vice President and Counsel, Massachusetts Mutual Life Insurance Company |