March 27, 2015

VIA EDGAR

The United States Securities and
Exchange Commission
100 F. Street, NE
Washington, D.C. 20549-8629

Re: Guaranteed Term Options

Nationwide Life Insurance Company
SEC File No. 333-200329
CIK 0000205695

Ms. Naseem Nixon:

On behalf of the registrant, please accept this filing of Post-Effective Amendment No. 1 to the Registration Statement on Form S-1 for the offering of guaranteed term options (GTOs) with a market value adjustment feature.

The purpose of this filing is to update all financial information as required by Form S-1. Other changes have also been made with the intent of clarifying the disclosure. These changes are noted in the electronic redlined copies. The materiality of the disclosure changes is consistent with the materiality of changes that would be filed pursuant to Rule 485(b).

We respectfully request an effective date of May 1, 2015. Please call me at (614) 677-6123 with your questions or comments.

Sincerely,

/s/ Ben Mischnick
Ben Mischnick
Assistant General Counsel
Nationwide Life Insurance Company