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.