Registrant:TIAA-CREF Life Insurance Company
8500 Andrew Carnegie Blvd.
(MS SSC-C2-08)
Charlotte, NC 28262
Kenneth W. Reitz
Associate General Counsel
Office: 704-988-4455
Fax: 704-988-1615
E-mail: kreitz@tiaa-cref.org
December 21, 2010
VIA EDGAR TRANSMISSION as CORRESPONDENCE
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Michael Kosoff – Office of Insurance Products
| Re: | TIAA-CREF Life Insurance Company (“Registrant”) | |
| File No. 333-149714 | ||
| POST-EFFECTIVE AMENDMENT #3 to the Registration | ||
| Investment Horizon Annuity, an individual flexible premium modified guaranteed annuity contract | ||
| Amendment #3 adds Individual Retirement Annuity and Flexible Lifetime Income Options. | ||
Dear Mr. Kosoff:
Today, we are filing, via EDGAR, the above-referenced amendment to the above-referenced registration. Amendment #3 amends the registration to permit the annuity contract to be issued on a non-qualified basis, or as an Individual Retirement Annuity. The Amendment also adds a new feature to provide Flexible Lifetime Income Options (“FLIO”). The Amendment also reflects changes in tax law, including regarding partial annuitizations. As a courtesy, we will e-mail to you a copy of today’s Amendment #3 marked to show changes from the currently-approved Investment Horizon Annuity prospectus. Other than obvious changes to make the contract eligible as an IRA, some of those changes that may be of interest in your review include:
| • | The FLIO feature provides a flexible income opportunity. FLIO allows the owner to receive lifetime income payments, while providing access to FLIO Account Balance as needed. When FLIO is elected, a separate FLIO account is established within the contract. The FLIO benefit guarantees a lifetime income beginning on a FLIO Income Security Date. Before the FLIO Income Security Date, the same income benefit is guaranteed as long as no excess withdrawals from the FLIO account are made, but will be reduced if excess withdrawals are made or will be eliminated if the FLIO account balance is completely withdrawn. |
| • | The FLIO account includes a market value adjustment (“MVA”) similar to the MVA feature levied upon a premature withdrawal under the base contract. |
| • | The FLIO account also includes a surrender charge for premature withdrawals. At the same time, we are eliminating the current surrender charge for the base contract. |
Amendment #3 is intentionally incomplete. Upon receiving Commission comments from the SEC reviewer, we intend to file a corrective Post-Effective Amendment #4 to address SEC reviewer comments and to include all information necessary for the Amendment to be declared effective, including 2010 financial statements.
The intended effective date for this Registration Amendment is May 1, 2011.
If you have any question concerning this information, please contact the undersigned by telephone at (704) 988-4455 or by e-mail atkreitz@tiaa-cref.org.
Respectfully Submitted,
/s/ Kenneth W. Reitz |
| Kenneth W. Reitz |
