SEC Company Response from TIAA-CREF FUNDS (CIK 0001084380) — Sep 22, 2025
TIAA-CREF FUNDS (CIK 0001084380)
Date: Sept. 22, 2025 · CIK: 0001084380 · Accession: 0000930413-25-002978
AI Filing Summary & Sentiment
File numbers found in text: 333-76651, 811-09301
Letter
Division of Investment Management 100 F Street NE Washington, DC 20549 Re: TIAA-CREF Funds Post-Effective Amendment No. 153 to Registration Statement on Form N-1A (File Nos. 333-76651, 811-09301)
Dear Ms. McManus:
On behalf of the TIAA-CREF Funds (the “Registrant” or the “Trust”), we are hereby responding to a comment provided to us telephonically on September 10 and 15, 2025 related to a comment you previously provided to us on August 14, 2025 regarding the Statement of Additional Information (“SAI”) for the Nuveen Lifecycle 2070 Fund and Nuveen Lifecycle Index 2070 Fund, each a series of the Registrant (the “Funds”) included in Post-Effective Amendment No. 153, which was filed on June 30, 2025 (the “Initial Filing”). Set forth below is our response to your comment. Terms used but not defined herein have the definition included in the SAI.
1. With respect to response five in your September 8, 2025 response to our prior comments on the Initial Filing, as drafted, the Funds’ concentration disclosure indicates they will not concentrate in any particular industry except real estate. The Funds do not specify any group of industries in which they will concentrate (as contemplated by the guidance you cited). Please revise to specify the group of industries in which the Funds will concentrate.
The Registrant confirms that the following language will be added to the end of the last paragraph in the “Investment objectives, policies, restrictions and risks–Fundamental policies” section of the SAI.
With respect to the limitation in number 8 above, the 1940 Act does not define what constitutes “concentration” in an industry. The SEC staff has taken the position that investment of 25% or more of a fund’s net assets in one or more issuers conducting their principal activities in the same industry or group of industries constitutes concentration. It is possible that interpretations of concentration could change.
* * * *
Kim McManus
September 22, 2025
Page 2
If you have any questions, please do not hesitate to call me at (704) 988-4101.
Very truly yours,
/s/ Jeremy D. Franklin
Show Raw Text
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
September 22, 2025
Kim McManus
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. 153 to Registration Statement on Form N-1A (File Nos. 333-76651, 811-09301)
Dear Ms. McManus:
On behalf of the TIAA-CREF Funds
(the “Registrant” or the “Trust”), we are hereby responding to a comment provided to us telephonically on September
10 and 15, 2025 related to a comment you previously provided to us on August 14, 2025 regarding the Statement of Additional Information
(“SAI”) for the Nuveen Lifecycle 2070 Fund and Nuveen Lifecycle Index 2070 Fund, each a series of the Registrant (the “Funds”)
included in Post-Effective Amendment No. 153, which was filed on June 30, 2025 (the “Initial Filing”). Set forth below is
our response to your comment. Terms used but not defined herein have the definition included in the SAI.
1.
With respect to response five in your September 8, 2025 response to our prior comments on the Initial
Filing, as drafted, the Funds’ concentration disclosure indicates they will not concentrate in any particular industry except real
estate. The Funds do not specify any group of industries in which they will concentrate (as contemplated by the guidance you cited). Please
revise to specify the group of industries in which the Funds will concentrate.
The Registrant
confirms that the following language will be added to the end of the last paragraph in the “Investment objectives, policies, restrictions
and risks–Fundamental policies” section of the SAI.
With respect to the limitation
in number 8 above, the 1940 Act does not define what constitutes “concentration” in an industry. The SEC staff has taken the
position that investment of 25% or more of a fund’s net assets in one or more issuers conducting their principal activities in the
same industry or group of industries constitutes concentration. It is possible that interpretations of concentration could change.
* * * *
Kim McManus
September 22, 2025
Page 2
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
Senior Managing Director, Managing Associate General Counsel
Rachael Zufall
Managing Director, Associate General Counsel