The Senate for the 28th Cosa consisted of seven seats.
The seat for Vuode was retained by the incumbent Harry Lee Madison.
The Senate seat for Atatürk was won by Weston John Erni, marking the first time a Senate seat had changed hands at the conclusion of a term of office.
The members of the Senate for the 28th Cosa, listed in the order of the scheduled expiration of their terms, were:
1 Senator Oplinger failed to vote in the final two Clarks, vacating his seat. It was filled by appointment to begin the 29th Cosa.
2 There is some evidence that Senator Muth's seat was vacant at the commencement of the first Clark and not voted for the first three Clarks. If he had indeed vacated the seat, he was reappointed and resumed his duties for the fourth Clark. As Senator Muth was the government of Mussolini at the time, the power to fill his seat would have resided in him.