# TIAA-CREF Tuition Financing, Inc.

> TIAA-CREF Tuition Financing, Inc. is an SEC-registered investment advisory firm in New York, NY, registered since 1999, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated June 16, 2026.

- CRD: 108580
- Filed as: TIAA-CREF TUITION FINANCING, INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: June 16, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/108580
- AdvisorCensus page: https://advisorcensus.com/firm/tiaa-cref-tuition-financing-inc-new-york-ny-108580

## Quick answers

**How is TIAA-CREF Tuition Financing, Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), TIAA-CREF Tuition Financing, Inc. reports these compensation arrangements: other. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is TIAA-CREF Tuition Financing, Inc. located?**
TIAA-CREF Tuition Financing, Inc.'s principal office is in New York, NY, according to its Form ADV; the July 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is TIAA-CREF Tuition Financing, Inc. registered with the SEC or a state?**
TIAA-CREF Tuition Financing, Inc. is an SEC-registered investment advisory firm, registered since 1999. Status as filed: Approved. CRD 108580.

**How much does TIAA-CREF Tuition Financing, Inc. manage?**
TIAA-CREF Tuition Financing, Inc. reports $70,511,420,455 in regulatory assets under management in its Form ADV filing dated June 16, 2026 (0% discretionary).

**How have TIAA-CREF Tuition Financing, Inc.'s assets and staff changed since 2021?**
In the Form ADV data for TIAA-CREF Tuition Financing, Inc.: Regulatory assets under management: $34,679,609,070 in the October 2021 data and $70,511,420,455 in the October 2026 data, up 103%. Total employees: 40 in October 2021 and 65 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does TIAA-CREF Tuition Financing, Inc. serve?**
By number of clients on Form ADV Item 5.D: state or municipal government entities (including government pension plans) (9).

**Which custodians does TIAA-CREF Tuition Financing, Inc. use?**
TIAA-CREF Tuition Financing, Inc.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Bank of New York Mellon Corp and Northern Trust Corp as custodians holding 10% or more of its separately managed account assets.

**Does TIAA-CREF Tuition Financing, Inc. report any disciplinary disclosures?**
Reports 2 disclosure items on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation) and 11.D(4) (another regulator's order in the past ten years). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/108580

**What changed in TIAA-CREF Tuition Financing, Inc.'s recent Form ADV filings?**
In the July 2026 filing data: Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- Other

### Custodians (Schedule D, Section 5.K(3))
- Bank of New York Mellon Corp
- Northern Trust Corp

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $70,511,420,455
- Discretionary: $0
- Non-discretionary: $70,511,420,455

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| State or municipal government entities (including government pension plans) | 9 | $70,511,420,455 |

### Advisory services (Item 5.G)
- Other

### Firm details
- Registered since: 1999 (27 years)
- Employees: 65 total, 5 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 2 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(4): In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/108580

### Other offices (Schedule D, Section 1.F), as of the July 2026 filing
- Charlotte, NC

### Websites listed on Form ADV (Item 1.I)
- [tiaa.org/public/invest/financial-products/529-college-savings](https://tiaa.org/public/invest/financial-products/529-college-savings)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $34,679,609,070 | 40 | June 7, 2021 |
| October 2022 | $40,836,795,937 | 41 | May 20, 2022 |
| October 2023 | $37,680,650,811 | 47 | March 30, 2023 |
| October 2024 | $43,091,355,901 | 46 | August 16, 2024 |
| October 2025 | $60,783,176,654 | 54 | May 7, 2025 |
| October 2026 | $70,511,420,455 | 65 | June 16, 2026 |

Regulatory assets under management: $34,679,609,070 in the October 2021 data and $70,511,420,455 in the October 2026 data, up 103%.
Total employees: 40 in October 2021 and 65 in October 2026.

## Changes in the filing (last 12 months)

### July 2026
- Updated its list of owners and control persons (Schedule A).

### April 2026
- Employees performing advisory functions went from 3 to 5.
- Regulatory assets under management went from $60,783,176,654 to $70,511,420,455 (+16%).
- Changed its office addresses in Charlotte, NC.
- No longer lists an office in New York, NY.

### December 2025
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. TIAA-CREF Tuition Financing, Inc. (CRD 108580): Form ADV filing data as of October 2026.