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Mr. David L. Orlic

Senior Counsel, Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Northwestern Mutual Variable Life Account II (“Registrant”)

Pre-Effective Amendments on Form N-6

File Nos. 333-230144 and 811-21933

File Nos. 333-230143 and 811-21933

Dear Mr. Orlic:

I am submitting this letter on behalf of the Company and its Registrant, as an addendum to our prior letter submitted to the SEC on June 3, 2019 (filed via Edgar as correspondence on June 4, 2019) (the “Proposed Response Letter”) in order to provide suggested revisions to certain proposed responses in the Proposed Response Letter per our telephonic conversations on July 8 and 16, 2019. The staff comments and proposed revised responses are summarized below and are intended to replace, in their entirety, the original responses in the Proposed Response Letter as enumerated below.

TRANSACTION FEES, PAGE 3

Comment:

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benefits, are reflected in the fee table.

Response:

The Company notes that the Policy Debt Expense Charges does not include any policy loan interest charge and therefore the disclosure in footnote 11 is correct. As we discussed, interest rates on loans are not subject to a fixed maximum like Policy fees, may vary by market and are out-of-pocket expenses to the Owner. The Company, therefore, does not consider this expense either a “recurring charge” required to be included in the Periodic Charges table (see Item 3 of Form N-6) or a “charge deducted from [the Policy]” (see Item 5 of Form N-6). The section entitled “Policy Loans” provides disclosure regarding how these rates are determined and how owners may obtain further information.

However, while not necessarily agreeing with the Staff’s characterization of this expense, for clarity and completeness the Registrant has added a row to the Periodic Charges table (under the Policy Debt Expense Charge) that substantially tracks existing narrative disclosure in the Policy Loans section as follows:

* There is no guaranteed maximum interest rate applied to loans taken against the Policy. The rate is intended to change to reflect changes in the interest rate environment. The maximum annual market loan rate shall not exceed the greater of the minimum guaranteed annual effective interest rate for the SAS Account Tier One Balance or the Moody’s Corporate Bond Yield Averages-Monthly Average Corporates rate for the immediately preceding October. (Please see “Policy Loans” for more information.)

In addition, the Company confirms that all rider chargers, including those for incidental benefits, are reflected in the fee table.

THE SEPARATE ACCOUNT, PAGE 7

Comment:

Response:

The Registrant has revised applicable disclosure to read:

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…transfer assets of the Separate Account in excess of reserve requirements (only for accrued fees and charges, any seed capital or in order to process transactions in compliance with Rule 22c-1 under the 1940 Act) applicable to the Policies supported by the Separate Account to the General Account (assets remaining in the Separate Account necessary to fulfill its obligations under the Policy are not subject to claims against or losses in the General Account);

ALLOCATION MODELS, PAGE 25

Comment:

Response:

As we discussed on our conference call on May 14, 2019, it is not the Company is not aware of a requirement to disclose model designations in the Registration Statement in circumstances where the models, as is the case here, are “static.” While, as the prospectus notes, models available to new purchasers may change from time to time, Owners are not reallocated to new model allocations unless specifically requested. However, the prospectus does provide general disclosure regarding the variety of models available and the Registrant has therefore revised applicable disclosure for additional clarity as follows:

Each of the four models currently available (Moderately Conservative, Balanced, Aggressive, Very Aggressive) is comprised of a combination of Portfolios representing various asset classes with various levels of risk tolerance ranging from moderately conservative to very aggressive. Generally, the four models can be characterized as follows:

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An Owner may only select a model which is currently available …

In addition, please note that the following disclosure has also been revised with respect to how owners may obtain information regarding the models:

An Owner should contact consult their Financial Representative for more information about available allocation models (including the specific asset mixes of available models) and whether investment in a model is appropriate for them.

* * *

Please call the undersigned with any questions or comments about this letter or if I can do anything to assist you in completing your review.

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