Correspondence 0001628280-24-018508 from TIAA REAL ESTATE ACCOUNT (CIK 0000946155)
TIAA REAL ESTATE ACCOUNT (CIK 0000946155)
Date: April 26, 2024 · CIK: 0000946155 · Accession: 0001628280-24-018508
AI Filing Summary & Sentiment
File numbers found in text: 333-277927
Letter
Document
TIAA Real Estate Account
c/o Teachers Insurance and Annuity Association of America
730 Third Avenue
New York, NY 10017
United States of America
Judy Bartlett, Esq.
Senior Director and Associate General Counsel
Product & Distribution Law
(914) 815-2026 (tele)
JUDY.BARTLETT@tiaa.org
April 26, 2024
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
202-551-3585 (tele)
Attention: Stacie Gorman
Re: TIAA Real Estate Account
Pre-Effective Amendment No. 1 to Registration Statement on Form S-1
(as amended, the “Registration Statement”) (File No. 333-277927)
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, the undersigned, on behalf of the TIAA Real Estate Account (the “Company”), hereby requests to accelerate the effectiveness date of the Company’s above-captioned Registration Statement for certain variable annuity contract accumulation units as soon as reasonably practicable by 9:00 a.m. EDT on Wednesday, May 1, 2024.
The Company hereby acknowledges that:
•should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
TIAA REAL ESTATE ACCOUNT
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Document
TIAA Real Estate Account
c/o Teachers Insurance and Annuity Association of America
730 Third Avenue
New York, NY 10017
United States of America
Judy Bartlett, Esq.
Senior Director and Associate General Counsel
Product & Distribution Law
(914) 815-2026 (tele)
JUDY.BARTLETT@tiaa.org
April 26, 2024
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
202-551-3585 (tele)
Attention: Stacie Gorman
Re: TIAA Real Estate Account
Pre-Effective Amendment No. 1 to Registration Statement on Form S-1
(as amended, the “Registration Statement”) (File No. 333-277927)
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, the undersigned, on behalf of the TIAA Real Estate Account (the “Company”), hereby requests to accelerate the effectiveness date of the Company’s above-captioned Registration Statement for certain variable annuity contract accumulation units as soon as reasonably practicable by 9:00 a.m. EDT on Wednesday, May 1, 2024.
The Company hereby acknowledges that:
•should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
•the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
TIAA REAL ESTATE ACCOUNT
By: TEACHERS INSURANCE AND ANNUITY
ASSOCIATION OF AMERICA
By: /s/ Judy Bartlett
Name: Judy Bartlett, Esq.
Title: Senior Director and Associate General Counsel