SEC Company Response from TIAA-CREF Life Insurance CO (CIK 0001429401) — Apr 29, 2020
TIAA-CREF Life Insurance CO (CIK 0001429401)
Date: April 29, 2020 · CIK: 0001429401 · Accession: 0001193125-20-126177
AI Filing Summary & Sentiment
File numbers found in text: 333-230440
Letter
VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Investment Management Re: TIAA-CREF Life Insurance Company (“Registrant”) Post-Effective Amendment #1 to the Registration Statement on Form S-1 Registration File No. 333-230440 Investment Horizon Annuity Contract
Dear Commissioners and Ms Vroman-Lee:
On this April 29, 2020, Registrant submits Post-Effective Amendment #1 to the Initial Registration Statement for the Investment Horizon Annuity contract.
LIMITED SCOPE OF CHANGES TO THE PROSPECTUS
Annual update changes
Changes in Post-Effective Amendment #1 to the Initial Registration Statement of the Investment Horizon Annuity are limited to current financial statements, consents, exhibits, and annual updated information, and a few minor non-material corrections and changes.
If the Post-Effective Amendment was eligible to be filed pursuant to Rule 485 under the Securities Act of 1933, the Registrant would have made the filing pursuant to Rule 485(b) because it does not include any material changes from previous filings. Internal counsel has reviewed the Registration Statement, and it does not include any disclosures that would render it ineligible to become effective under Rule 485(b) (assuming that the Registration Statement would be eligible for Rule 485 generally).
For these reasons, REGISTRANT REQUESTS AN ACCELERATED EFFECTIVE DATE OF MAY 1, 2020 FOR THIS REGISTRATION.
TIAA PUBLIC
TANDY REPRESENTATIONS
The Registrant hereby acknowledges:
•
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 Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing; and
•
The Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any question concerning this filing, please contact our counsel, John D. Piller, by telephone at (704) 988-5681 or by e-mail at jpiller@tiaa.org.
Respectfully Submitted,
/s/ William G.
Griesser
Show Raw Text
CORRESP 1 filename1.htm Acceleration Request TIAA PUBLIC Registrant: TIAA-CREF Life Insurance Company 8500 Andrew Carnegie Blvd. (MS SSC-C2-08) Charlotte, NC 28262 John D. Piller, Sr. Director, Associate General Counsel TFS Law Office: 704-988-5681 Fax: 704-988-1615 E-mail: jpiller@tiaa.org April 29, 2020 VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Investment Management Disclosure Review & Accounting Office 100 F Street, N.E. Washington, D.C. 20549 Attn: Ashley Vroman-Lee Re: TIAA-CREF Life Insurance Company (“Registrant”) Post-Effective Amendment #1 to the Registration Statement on Form S-1 Registration File No. 333-230440 Investment Horizon Annuity Contract Dear Commissioners and Ms Vroman-Lee: On this April 29, 2020, Registrant submits Post-Effective Amendment #1 to the Initial Registration Statement for the Investment Horizon Annuity contract. LIMITED SCOPE OF CHANGES TO THE PROSPECTUS Annual update changes Changes in Post-Effective Amendment #1 to the Initial Registration Statement of the Investment Horizon Annuity are limited to current financial statements, consents, exhibits, and annual updated information, and a few minor non-material corrections and changes. If the Post-Effective Amendment was eligible to be filed pursuant to Rule 485 under the Securities Act of 1933, the Registrant would have made the filing pursuant to Rule 485(b) because it does not include any material changes from previous filings. Internal counsel has reviewed the Registration Statement, and it does not include any disclosures that would render it ineligible to become effective under Rule 485(b) (assuming that the Registration Statement would be eligible for Rule 485 generally). For these reasons, REGISTRANT REQUESTS AN ACCELERATED EFFECTIVE DATE OF MAY 1, 2020 FOR THIS REGISTRATION. TIAA PUBLIC TANDY REPRESENTATIONS The Registrant hereby acknowledges: • 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 Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing; and • The Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you have any question concerning this filing, please contact our counsel, John D. Piller, by telephone at (704) 988-5681 or by e-mail at jpiller@tiaa.org. Respectfully Submitted, /s/ William G. Griesser William G. Griesser President and Chief Executive Officer TIAA-CREF Life Insurance Company /s/ Angela M. Kahrmann Angela M. Kahrmann President and Chief Operating Officer TIAA-CREF Individual & Institutional Services, LLC (Principal Underwriter)