Registrant:TIAA-CREF Life Insurance Company
8500 Andrew Carnegie Blvd.
(MS SSC-C2-08)
Charlotte, NC 28262
Contact:
Kenneth W. Reitz
General Counsel
Office: 704-988-4455
E-mail: kreitz@tiaa.org
March 23, 2016
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Deborah Skeens – Office of Insurance Products
| Re: | TIAA-CREF Life Insurance Company (“Registrant”) |
| New Registration of previously registered Form S-1 Annuity Contract |
| Former Registration File No. 333-187638 |
| Investment Horizon Annuity Contract |
Dear Commissioners and Ms. Skeens:
Form S-1 annuity contracts must be reregistered every three years. Today, Registrant is submitting a new Initial Registration for the Investment Horizon Annuity contract. This contract was previously registered as File No. 333-187638. Today’s new registration includes only minimal changes from Registration No. 333-187638 – primarily annual update changes. A courtesy copy marked to show changes from Registration No. 333-187638 is being provided to Ms. Skeens by e-mail. This new Initial Registration is intentionally incomplete, since Registrant will not have requisite 2015 audited financial statements and certain updated information until mid-April. Registrant intends to submit a pre-effective amendment to complete the new Registration.
Registrant requests an accelerated effective date of May 1, 2016 for this new Initial Registration of the Investment Horizon Annuity.
LIMITED SCOPE OF CHANGES TO THE PROSPECTUS
Annual update changes
Changes in this new Initial Registration of the Investment Horizon Annuity from Registration No. 333-187638 are limited to annual updated information and a few minor corrections. Incomplete information, such as updated financial statements, will be provided in a pre-effective amendment prior to May 1, 2016.
A courtesy marked copy of these changes and a copy of this letter was provided to Ms. Skeens by e-mail on the date of this letter.
All other provisions to the contract prospectus remain unchanged from the prospectus currently in use as Registration No. 333-187638.
TANDY REPRESENTATIONS
The Registrant hereby acknowledges:
| • | Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing; and |
| • | The Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
WE REQUEST ACCELERATION OF THE EFFECTIVE DATE OF THIS REGISTRATION TO MAY 1, 2016.
If you have any question concerning this filing, please contact our Associate General Counsel, Nathaniel Kunkle, by telephone at (704) 988-0371 or by e-mail at nathaniel.kunkle@tiaa.org.
Respectfully Submitted,
/s/ Kenneth W. Reitz
Kenneth W. Reitz
General Counsel
TIAA-CREF Life Insurance Company
