Correspondence 0001193125-24-227580 from TIAA-CREF FUNDS (CIK 0001084380)
TIAA-CREF FUNDS (CIK 0001084380)
Date: Sept. 27, 2024 · CIK: 0001084380 · Accession: 0001193125-24-227580
AI Filing Summary & Sentiment
File numbers found in text: 811-09301
Letter
VIA EDGAR Division of Investment Management, Disclosure Review & Accounting Office 100 F Street, N.E. Washington, D.C. 20549 Re: Comments on Tailored Shareholder Reports for TIAA-CREF Funds (Investment Company Act File No. 811-09301)
Dear Mr. Kosoff:
On behalf of TIAA-CREF Funds (the “Registrant”), we are responding to comments received from you telephonically on August 28, 2024 based on your review of the Registrant’s May 31, 2024 Annual Shareholder Report filed on Form N-CSR as of August 6, 2024 (the “Report”).
Set forth below are the SEC staff’s comments on the Report followed by responses on behalf of the Registrant. Capitalized terms used herein have the same meaning as in the Report.
1. With respect to the Fund Expenses Example, the Form N-1A instructions state, “to determine ‘Costs of a $10,000 investment,’ multiply the figure in the ‘Cost paid as a percentage of your investment’ column by the average annual account value over the period based on an investment of $10,000 at the beginning of the period” (emphasis added). The computation included in the Report appears to be the Fund expenses multiplied by $10,000 rather than the Fund expenses multiplied by the average annual account value over the period based on an investment of $10,000 at the beginning of the period.
Response: The Registrant will include in future shareholder reports the computation for Fund Expenses Example as provided in Form N-1A, Item 27A(c), Instruction 2.
2. Ensure that any Average Annual Total Returns table with multiple indexes has correctly XBRL-tagged each index as either a “broad-based” or “additional” index, as applicable.
Response: The Registrant will ensure that such indexes are tagged correctly in future shareholder reports.
Michael Kosoff
September 27, 2024
Page
* * * *
If you have any questions, please do not hesitate to call me at (202) 261-3464.
Sincerely,
/s/ Adam T. Teufel
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CORRESP 1 filename1.htm CORRESP 1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com ADAM T. TEUFEL adam.teufel@dechert.com +1 202 261 3464 Direct +1 202 261 3164 Fax September 27, 2024 VIA EDGAR Michael Kosoff U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review & Accounting Office 100 F Street, N.E. Washington, D.C. 20549 Re: Comments on Tailored Shareholder Reports for TIAA-CREF Funds (Investment Company Act File No. 811-09301) Dear Mr. Kosoff: On behalf of TIAA-CREF Funds (the “Registrant”), we are responding to comments received from you telephonically on August 28, 2024 based on your review of the Registrant’s May 31, 2024 Annual Shareholder Report filed on Form N-CSR as of August 6, 2024 (the “Report”). Set forth below are the SEC staff’s comments on the Report followed by responses on behalf of the Registrant. Capitalized terms used herein have the same meaning as in the Report. 1. With respect to the Fund Expenses Example, the Form N-1A instructions state, “to determine ‘Costs of a $10,000 investment,’ multiply the figure in the ‘Cost paid as a percentage of your investment’ column by the average annual account value over the period based on an investment of $10,000 at the beginning of the period” (emphasis added). The computation included in the Report appears to be the Fund expenses multiplied by $10,000 rather than the Fund expenses multiplied by the average annual account value over the period based on an investment of $10,000 at the beginning of the period. Response: The Registrant will include in future shareholder reports the computation for Fund Expenses Example as provided in Form N-1A, Item 27A(c), Instruction 2. 2. Ensure that any Average Annual Total Returns table with multiple indexes has correctly XBRL-tagged each index as either a “broad-based” or “additional” index, as applicable. Response: The Registrant will ensure that such indexes are tagged correctly in future shareholder reports. Michael Kosoff September 27, 2024 Page 2 * * * * If you have any questions, please do not hesitate to call me at (202) 261-3464. Sincerely, /s/ Adam T. Teufel Adam T. Teufel cc: John McCann, Vice President and Assistant Secretary of the Funds; Managing Director and Associate General Counsel, Nuveen; Richard Biegen, Chief Compliance Officer of the Funds; Senior Managing Director, TIAA; Eric Fess, Chapman & Cutler, LLP, Counsel to the Independent members of the Board of Directors/Trustees of the Funds; Robert Zutz, K&L Gates LLP, Counsel to the Independent members of the Board of Directors/Trustees of the Funds