Regulation best interest disclosure - TIAA

1 Regulation best interest disclosureFor over 100 years, TIAA has served the retirement needs of people who work in the academic, medical, cultural and research fields, and their families. Our goal is to help you pursue financial well-being throughout your life through a variety of investing solutions.* TIAA provides broker-dealer services through its affiliate TIAA-CREF Individual & Institutional Services, LLC ( TC Services ) and its registered representatives ( Financial Professionals ). We are required to provide this document to you as a retail customer1 under the SEC s Regulation Best interest . You may receive this document multiple times, depending on the products and services you have with us. You should review this document (and any updates and revisions to it) when you receive any securities recommendations (including investment strategies involving securities) from us. We refer to TC Services and its Financial Professionals collectively as we / us / our throughout this Retail customers are natural persons, or their legal representatives that use recommendations primarily for personal, family or household purposes.

2 This document is not intended for plan sponsors or nonretail of November 15, 2021 This document describes the products and services we provide as a broker-dealer registered with the Securities and Exchange Commission ( SEC ).* It can help you understand important information about the recommendations we provide such as the fees we charge and how we are paid for these services. Specifically, this document provides information on: WOur broker-dealer services WThe standard of conduct that applies to any recommendation (including investment strategies involving securities) we provide for your TIAA accounts when we act as a broker-dealer as well as important considerations (including conflicts) and limitations related to our recommendations WThe accounts, products and services we may recommend as a broker-dealer (called Solutions in this document) as well as our fees and other compensation WOur investment philosophy, the general basis for our recommendations and risks of investing WOur Financial Professionals roles, how they are compensated and material conflicts of interest related to their compensationOur solutionsMost, but not all, of our clients begin their relationship with us when they enroll in an employer-sponsored retirement plan ( Plan ) at TIAA.

3 For clients with investing needs beyond their Plan(s), we offer a range of Solutions, such as affiliated individual retirement accounts ( IRAs ), self-directed brokerage accounts, variable annuities and variable universal life insurance through third parties. All Solutions are described in more detail starting on page 8. We also offer services as a registered investment adviser and services from our affiliates (collectively, Other Services ), which are summarized starting on page 25. Please review all documents and disclosures associated with Solutions and Other Services we recommend to make fully informed decisions. If you have a Plan that is recordkept by TIAA as a service provider, we may use data from your Plan when we recommend or provide you with Solutions and Other Services. Plan sponsors do not review or endorse any Solutions or Other Services outside of their Our broker-dealer services ..3 Our recommendations ..4 The best interest standard applicable to our recommendations 4 Fiduciary Acknowledgment re: Certain Retirement Plan Recommendations.

4 4 Limitations on our Recommendations: Affiliated products and related conflicts of interest ..4 Types of affiliated products and conflicts of interest ..5 Affiliated funds from the TIAA-CREF and Nuveen family of mutual funds ( Affiliated Funds ) ..5 Retirement annuities issued by TIAA and CREF, including: ..5 Other affiliated products ..5 Third-party products and conflicts of interest ..6 Limited buy and sell recommendations ..6No monitoring of our recommendations ..6 Important IRA rollover and account transfer considerations ..6 Important annuitization considerations ..7 Our solutions ..8 Plan accounts recordkept by TIAA ..8 TIAA IRAs* ..9 TIAA brokerage accounts ..11 Retail variable annuities from TIAA and its affiliates ..12 Variable life insurance through third parties ..14 Our investment philosophy and the general basis for our recommendations ..15 Risks of investing.. 16 Our financial professionals and their compensation ..18 National Contact Center financial services consultants.

5 18 Financial consultants ..19 Individual financial consultants ..19 Advisory consultants ..20 Wealth management advisors ..21 Life and annuity specialists ..24 Managers of financial professionals ..24 Additional compensation from third parties ..24 Other services ..25 Our investment advisory services ..25 Financial planning services ..25 Managed account solutions ..25 Investment management services through TIAA Bank ..25 Referrals to TIAA affiliates ..25 Insurance agents offering annuity and life insurance products ..25 Appendix A ..26 Fees imposed by third-party life carriers for variable universal life policies ..26 Regulation best interest disclosure - November 15, 2021 2 WOpen, contribute or enroll in our Solutions, including consolidating assets via an IRA or plan rollover or transfer WCreate a lifetime income stream by annuitizing affiliated variable annuity holdings at TIAA WPurchase and sell specific investments within your Plans at TIAA (where available), the TIAA IRAs and certain TIAA-CREF Life Insurance Company ( TIAA Life ) annuities WPurchase third-party variable universal life insurance policiesRecommendations to enroll in, roll over to or contribute more to a TIAA professionally managed account are provided as registered investment adviser services and not as broker-dealer services.

6 You will be provided with a separate disclosure document for managed account recommendations. For more information about our and our affiliates advisory programs and offerings, see the program disclosure documents at and the applicable client also offer educational services as a broker-dealer that do not involve a Recommendation, including: WInformation about investing WInformation about Solutions available at TIAA WEducation and enrollment services, including help with contributions, servicing and distribution needs for your TIAA Plans and other TIAA accounts WVarious online tools and calculators available through broker-dealer services are provided based on your needs at the time of the broker-dealer servicesWe act as a broker-dealer when we buy and sell securities for your TIAA accounts at your direction. From time to time, we may also provide you with investment recommendations as part of our broker-dealer services ( Recommendations ).

7 Specifically, we can provide Recommendations to: Regulation best interest disclosure - November 15, 2021 3 Fiduciary Acknowledgment re: Certain Retirement Plan Recommendations Covered recommendations that we make involving employer retirement plans subject to the Employee Retirement Income Security Act of 1974 ( ERISA ) and individual retirement accounts ( IRAs ) subject to the Internal Revenue Code ( IRC ) (collectively, plans ) are subject to a fiduciary duty under ERISA and the IRC, respectively. Covered recommendations include rollover/transfer recommendations, annuitization recommendations and recommendations to enroll in an IRA ( covered investment advice ). When we provide covered investment advice to you regarding your plan(s), the way we make money creates some conflicts with your interests, so we operate under impartial conduct standards and internal policies and procedures that require us to act in your best interest and not put our interests ahead of yours.

8 When we provide investment advice to you regarding your plan(s), we are fiduciaries within the meaning of Title I of ERISA and the Code, as applicable. Certain employer retirement plans (like governmental plans) are not covered by ERISA and its impartial conduct standards. However, our internal policies and procedures require us to adhere to the same fiduciary standard and requirements when we provide you with covered investment advice on non-ERISA plan assets. Limitations on our Recommendations: Affiliated products and related conflicts of interestMany of our Solutions include affiliated mutual funds and annuities ( Affiliated Products ). Below are descriptions of the Affiliated Products we offer within various Solutions and how we and our affiliates are compensated for them. Recommending Solutions that include Affiliated Products to you creates a conflict of interest because we and our affiliates receive additional compensation when you invest in them.

9 We generally receive more compensation for the sale of Affiliated Products than for the sale of third-party products. You may be able to obtain similar investment products and services from another financial institution at a lower recommendationsThe best interest standard applicable to our recommendationsOur Recommendations are subject to a standard under the SEC s Regulation Best interest that requires us to act in your best interest when making a Recommendation and without placing our financial or other interests ahead of yours. Regulation Best interest does not require or ensure that: 1) we recommend the lowest-cost option; 2) we guarantee the performance of any investment; or 3) your investment objectives will be achieved. In addition, we are not responsible for actions you take that are different from or inconsistent with our Recommendations. You assume the risk of such decisions. We are not responsible for your delay in implementing a Recommendation.

10 If you delay acting upon a Recommendation, please review the latest version of this document before taking action, as the content may have changed, and speak with a Financial Professional about whether the Recommendations continue to be in your best interest . Visit or call 888-583-2535 to request the latest version of this document. Regulation best interest disclosure - November 15, 2021 4 Types of affiliated products and conflicts of interestAffiliated funds from the TIAA-CREF and Nuveen family of mutual funds ( Affiliated Funds )We earn distribution and sub-transfer agency fees for services performed for the Affiliated Funds, whether held directly with the Affiliated Funds or within a TC Services account. Other TIAA affiliates also earn compensation for providing administrative, recordkeeping and investment management services. The compensation we and our affiliates earn is set forth in the prospectus clients will receive at or before the mutual fund shares are delivered.