SecProbe.io

CORRESP
1
filename1.htm

    Jeremy D. Franklin

    Managing Director, Associate General Counsel

    8500 Andrew Carnegie Blvd.

    Charlotte, NC 28262

    T 704.988.4101

    jeremy.franklin@nuveen.com

July 18, 2024

Ashley Vroman-Lee

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

 Re: TIAA-CREF Funds Post-Effective Amendment No. 146 to Registration Statement on Form N-1A (File Nos. 333-76651, 811-09301)

Dear Ms. Vroman-Lee:

On behalf of the TIAA-CREF Funds (the “Registrant”
or the “Trust”), we are hereby responding to comments provided to us telephonically on July 11, 2024 regarding the Prospectus
and Statement of Additional Information (“SAI”) for the series of the Registrant (the “Funds”) included in Post-Effective
Amendment No. 146, which was filed on May 23, 2024 (the “initial filing”). Set forth below are our responses to your comments
on the initial filing. Terms used but not defined herein have the definition included in the Prospectus.

1. For
each Fund, there is missing information in the initial filing, including fees, expense examples and performance information. Please include
this information in the correspondence filing.

The fees,
expense examples and performance information for each Fund are attached as Appendix A hereto.

2. For
all Funds with “Floating and Variable Rate Securities Risk” as a principal risk, please include in the principal strategies
section disclosure that such Funds may invest in floating and variable rate securities.

The Registrant
will add disclosure regarding the fact that a Fund may invest in floating and variable rate securities in the principal strategies section
of each Fund that includes “Floating and Variable Rate Securities Risk” as a principal risk, to the extent such Fund does
not already include such disclosure.

3. For
each Fund that includes “Derivatives Risk” as a principal risk, we note that such risk disclosure does not include the specific
derivatives in which a Fund may invest, while the principal strategies section does include such disclosure. Please note in the “Derivatives
Risk” section the specific derivatives in which a Fund may invest.

Ashley Vroman-Lee

July 18, 2024

Page 2

The Registrant
will revise the “Derivatives Risk” disclosure for each Fund to note the types of derivatives that are listed in the Fund’s
principal strategies. For example, for Nuveen Core Bond Fund, the “Derivatives Risk” will be updated to the following:

Derivatives Risk—The risks associated with investing in derivatives,
including futures, options, swaps, forwards, and other fixed-income derivative instruments, and other similar instruments (referred to
collectively as “derivatives”) may be different and greater than the risks associated with directly investing in the underlying
securities and other instruments, and include leverage risk, market risk, counterparty risk, liquidity risk, operational risk and legal
risk. The Fund may use more complex derivatives that might be particularly susceptible to liquidity, credit and counterparty risk. When
investing in derivatives, the Fund may lose more than the principal amount invested.

4. For
Nuveen Core Impact Bond Fund, Nuveen Short Duration Impact Bond Fund, and Nuveen Green Bond Fund, we note that the terms “impact”
and “green” in a Fund’s name require an 80% test that covers the relevant term. Our position is that “impact”
and “green” are subject to Rule 35d-1 and therefore require an 80% policy.

The Registrant respectfully declines to amend these
Funds’ prospectuses to include an 80% test related to “impact” or “green” in the applicable Fund names at
this time. Notwithstanding the response set forth below, the Registrant acknowledges the recent amendments to Rule 35d-1 and is currently
evaluating the impact of the amendments on these Funds to determine whether changes to the Fund names and/or 80% policies may be needed
on or before December 11, 2025, which is the compliance date for the recent amendments to Rule 35d-1.

Rule 35d-1, as in effect at the time each of these
Funds commenced operations, required that a Fund adopt an 80% policy in three situations: (i) when it has a name suggesting investment
in certain investments or industries; (ii) when it has a name suggesting investment in certain countries or geographic regions; and (iii)
when it has a name suggesting it is exempt from federal income tax or from both federal and state income tax. For that reason, the Nuveen
Green Bond Fund, for example, has a policy to invest at least 80% of its assets in bonds, since the Fund’s name suggests that it
focuses its investments in bonds.

However, the Registrant does not believe
that the term “impact” or “green” is a term that falls under any of the three categories outlined in Rule 35d-1
(as in effect at the time the Funds commenced operations). Neither “impact” nor “green” suggests investment in
certain industries, countries or geographic regions or suggest that a Fund is exempt from any tax. The Registrant also does not believe
that either term is a term that suggests that a Fund focuses its investments in a particular type of investment or investments. The term
“impact” is used to suggest the Fund’s strategy of using environmental, social and governance (“ESG”) criteria,
together with TIAA’s proprietary Impact framework, in making its investments. Similarly, “green” is used to suggest
the Fund’s strategy of investing in issuers with certain environmental characteristics. Neither the ESG criteria and Impact framework,
nor the “green” strategy, require a Fund to invest in a particular type of investment or investments, but rather such terms
connote an investment strategy, which does not implicate Rule 35d-1 as currently applicable to the Funds.

Ashley Vroman-Lee

July 18, 2024

Page 3

5. For
the Nuveen Core Impact Bond Fund, Nuveen Short Duration Impact Bond Fund, Nuveen Short Term Bond Fund and Nuveen Short Term Bond Index
Fund, each Fund’s principal strategies disclosure notes that the Fund may invest in emerging markets fixed-income securities, but
there is no corresponding risk disclosure for emerging markets investments. Please include for each such Fund a corresponding principal
risk disclosure.

The Registrant
respectfully notes that each Fund, in its “Fixed-Income Foreign Investment Risk,” includes disclosure about the fact that
the risks of investing in fixed-income foreign investments “are heightened in emerging or developing markets.” However, the
Registrant will additionally add a separate emerging markets risk disclosure for each of these Funds.

6. For
the Nuveen Core Bond Fund, Nuveen Core Impact Bond Fund, Nuveen Core Plus Bond Fund, Nuveen Green Bond Fund and Nuveen Short Duration
Impact Bond, please disclose a risk for relative value trading in their principal risks, given the reference to each Fund’s use
of relative value trading in the Funds’ principal strategies.

As disclosed
in each Fund’s principal strategies, the use of relative value trading may increase a Fund’s portfolio turnover rate. Other
than the Nuveen Green Bond Fund, each Fund currently discloses the following principal risk related to portfolio turnover:

Portfolio Turnover Risk—Depending
on market and other conditions, the Fund may experience high portfolio turnover, which may result in greater transactional expenses, such
as brokerage commissions, bid-ask spreads, or dealer mark-ups, and capital gains (which could increase taxes and, consequently, reduce
returns).

With respect
to the Nuveen Green Bond Fund, its portfolio turnover rate has been relatively low, and the Registrant does not currently anticipate any
material increase in the Fund’s portfolio turnover rate.

In addition,
each Fund’s principal strategies describe the active nature of the relative value strategy. Each Fund’s principal risk disclosure
includes the following principal risk regarding active management:

Active Management
Risk—The risk that Advisors’ strategy, investment selection or trading execution may cause the Fund to underperform relative
to the benchmark index or mutual funds with similar investment objectives and may not produce expected returns.

The Registrant
therefore respectfully submits that the Funds’ current disclosure includes the principal risks of relative value trading, and no
additional risk disclosure is necessary.

7. For
the Nuveen 5-15 Year Laddered Tax Exempt Bond Fund, we note that the Fund’s principal strategies say it may invest in private activity
bonds. Please include any risk disclosure related to investments in such bonds.

Ashley Vroman-Lee

July 18, 2024

Page 4

The Registrant
notes that the current principal strategies disclosure of the Fund includes information regarding the tax treatment of private activity
bonds. Otherwise, the Registrant respectfully believes that the principal risks of investing in private activity bonds are included in
the Fund’s current principal risks disclosure, including in “State and Municipal Investment Risk,” which discloses the
risks of investment in tax-exempt bonds and other municipal securities, and no additional risk disclosure is necessary in the Prospectus.
However, the Registrant has revised the disclosure regarding private activity bonds in the “Municipal securities” section
of the SAI to the following:

Municipal securities generally
are understood to include debt obligations issued to obtain funds for various public purposes, including the construction of a wide range
of public facilities, refunding of outstanding obligations, payment of general operating expenses and extensions of loans to public institutions
and facilities. Private activity bonds that are issued by or on behalf of public authorities to finance privately operated facilities
are considered to be municipal securities if, in the opinion of the issuer’s counsel, the interest paid on them qualifies as excluded
from gross income (but not necessarily from alternative minimum taxable income) for federal income tax purposes. Interest on certain “private
activity” bonds is subject to federal AMT. Interest from private activity bonds is a tax preference item for the purposes of determining
whether a taxpayer is subject to the AMT and the amount of AMT to be paid, if any. Private activity bonds are secured primarily by revenues
derived from loan repayments or lease payments due from the entity, which may or may not be guaranteed by a parent company or otherwise
secured. Private activity bonds generally are not secured by a pledge of the taxing power of the issuer of such bonds. Therefore, repayment
of such bonds generally depends on the revenue of a private entity. The continued ability of an entity to generate sufficient revenues
for the payment of principal and interest on such bonds will be affected by many factors, including the size of the entity, its capital
structure, demand for its products or services, competition, general economic conditions, government regulation and the entity’s
dependence on revenues for the operation of the particular facility being financed.

8. For
the Nuveen Green Bond Fund, Nuveen High Yield Fund, Nuveen Inflation Linked Bond Fund, Nuveen Short Duration Impact Bond Fund, Nuveen
Short Term Bond Fund, Nuveen Short Term Bond Index Fund and Nuveen Real Estate Securities Select Fund, we note that each Fund’s
previous benchmark will no longer qualify as an appropriate broad-based securities market index. Please explain to us what the appropriate
broad-based securities market index of each Fund will be.

For each
Fund other than the Nuveen Real Estate Securities Select Fund, the appropriate broad-based securities market index will be the Bloomberg
U.S. Aggregate Bond Index, and for the Nuveen Real Estate Securities Select Fund, it will be the S&P 500 Index. Please see Appendix
A for updated performance tables for each Fund with the new broad-based securities market indexes added.

Ashley Vroman-Lee

July 18, 2024

Page 5

9. For
the Nuveen Money Market Fund, please include risk disclosure regarding investing in money market securities, U.S. Treasury bonds and U.S.
Treasury inflation indexed securities.

The Registrant
notes that the Fund is a “government money market fund” that invests at least 99.5% of its total assets in cash, U.S. Government
securities and/or repurchase agreements that are collateralized fully by cash or U.S. Government securities. The Registrant respectfully
believes that the Fund’s principal risks disclose the risks of investing in such securities, including through the current “U.S.
Government Securities Risk,” and that no additional risk disclosure is necessary.

10. For
the Nuveen Money Market Fund, Nuveen Short Duration Impact Bond Fund and any other Fund focusing on investments in short-term instruments,
please include the risk of investing in short-term instruments.

The Registrant
will add the following language in the existing “Interest Rate Risk” disclosure in each Fund:

When interest rates change,
the values of longer duration fixed-income securities usually change more than the values of shorter duration fixed-income securities.
Conversely, fixed-income securities with shorter durations or maturities will be less volatile but may provide lower returns than fixed-income
securities with longer durations or maturities.

11. For
the Nuveen Real Estate Securities Select Fund, the Fund’s principal risks include risks related to investments in securities of
all market capitalizations. Please tie this risk disclosure back to the principal strategies.

The Fund’s
principal strategies do not focus on market capitalization, and therefore the market capitalization of the Fund may vary over time. Therefore,
the Registrant respectfully believes that the Fund’s current principal strategies disclosure is appropriate.

12. We
note that in the disclosure regarding the portfolio management teams required by Item 10(a)(2) of Form N-1A, it discusses how different
portfolio managers may have different responsibilities but does not say whether the portfolio managers are jointly responsible for managing
a Fund’s investments. Form N-1A requires a registrant to state whether the portfolio managers are jointly responsible, or to alternatively
delineate responsibilities.

Item 10(a)(2)
of Form N-A does not prescribe specific language to be used in identifying the portfolio managers. The Registrant respectfully believes
its current formulation is responsive to Item 10(a)(2) and is the most accurate description of the portfolio managers’ role in managing
the Funds.

13. We
note that the Funds’ financial highlights are not included. Please include in a subsequent filing.

The Funds’
financial highlights will be included in the Registrant’s filing pursuant to Rule 485(b) under the Securities Act of 1933, as amended.

Ashley Vroman-Lee

July 18, 2024

Page 6

* * * *

If you have any questions, please do not hesitate
to call me at (704) 988-4101.

    Very truly yours,

    /s/ Jeremy D. Franklin

    Jeremy D. Franklin

    cc:
    John McCann

    Managing Director, Managing Associate General Counsel

    Rachael Zufall

    Managing Director, Associate General Counsel

Ashley Vroman-Lee

July 18, 2024

Page 7

Appendix A

Nuveen Bond Index Fund

Fees

SHAREHOLDER FEES (fees
paid directly from your investment)

    Class
    A

    Class I

    Premier

    Class

    Class R6

    Retirement

    Class

    Class
    W

    Maximum
    sales charge (load) imposed on purchases (as a percentage of offering price)
    3.75%

    0%

    0%

    0%

    0%

    0%

    Maximum
    deferred sales charge (load)
    0%

    0%

    0%

    0%

    0%

    0%

    Maximum
    sales charge (load) imposed on reinvested dividends and other distributions
    0%

    0%

    0%

    0%

    0%

    0%

    Redemption
    or exchange fee
    0%

    0%

    0%

    0%

    0%

    0%

    Annual