This is a wrap fee program, meaning the stated fee covers investment advice, portfolio management, and other services. Affiliated Funds are included in substantially all of the Program’s model portfolios. TIAA affiliates earn compensation for advisory, distribution, and administrative services provided to the Affiliated Funds, resulting in the receipt of two levels of fees by TIAA and its affiliates. The program seeks to mitigate this conflict for IRAs and Program accounts subject to the IRC and ERISA (but not taxable accounts) by providing fee credits to offset the underlying fund affiliated management fees and to all Program accounts by providing reimbursements of Rule 12b-1 fees and Other Fund Fees.