9AT: TIAA-CREF TUITION FINANCING, INC.

TIAA-CREF TUITION FINANCING, INC.

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TIAA-CREF TUITION FINANCING, INC.

Adviser Profile

As of Date	03/12/2026
ADV Location	NEW YORK, NY, United States
Adviser Type - Large advisory firm
Number of Employees	65 41%
of those in investment advisory functions	5 67%
Registration	SEC, Approved, 09/10/1999

AUM^*	70,511,420,455 64%
of that, discretionary	0
Private Fund GAV^*	0
Avg Account Size	7,834,602,273 27%
SMA’s	Yes
Private Funds	0
Contact Info	212 xxxxxxx
Websites

Client Types

- State or municipal government entities

Advisory Activities

Compensation Arrangments

Reported AUM

41B 35B 29B 23B 18B 12B 6B

2015 2016 2017 2018 2019 2020 2021 2022 2023

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Brochure Summary

Overview

TFI is a wholly owned subsidiary of Teachers Insurance and Annuity Association of America (“TIAA”) and is registered with the SEC as an investment adviser and as a municipal advisor. TFI provides program management services to qualified tuition programs formed by states, state agencies, or educational institutions under Section 529 and 529A of the Internal Revenue Code (“529 Plans”). TFI has provided such services to 529 Plans since its incorporation in 1998. TFI provides various program management services, including investment recommendations to State entity clients (“States”) that establish and maintain 529 Plans. TFI’s investment advisory services are limited to providing investment recommendations to State entities only. TFI has no investment advisory clients other than these State entities. TFI recommends investment options and underlying investment vehicles and provides advice as to how each portfolio should be allocated among the underlying investment

vehicles for a State’s 529 Plan. TFI’s recommendations are specific to and intended to be consistent with each State’s investment policy statement and/or guidelines for its 529 Plan, if applicable. Each State client, which retains the full investment authority for its 529 Plan, may impose various restrictions, as well as approve, reject, or revise TFI’s recommendations. TFI does not exercise investment discretion in connection with selecting and retaining 529 Plan investment options. TFI’s expertise lies in structuring investment options for 529 Plans that change asset allocations dynamically over time, as beneficiaries approach school enrollment. These options (i) provide efficient, auto- rebalancing of portfolios, and (ii) seek to provide appropriate levels of risk and return according to the expected school enrollment years. As of December 31, 2023, assets in 529 Plans to which TFI provides investment advisory services totaled $43,091,355,901.04.