How do we report holdings in the TIAA Real Estate Account under the revised Form 5500?
If your plans have any participants who participated in the TIAA Real Estate Account at any time during the plan year, you must comply with the instructions for reporting these assets applicable to plans that invest in a so-called “Direct Filing Entity.” The TIAA Real Estate Account is a pooled separate account or “PSA” of TIAA, an insurance company, and is therefore a Direct Filing Entity for Form 5500 reporting purposes. On behalf of the Real Estate Account, TIAA will file a Form 5500 directly with the DOL, which will permit plans with assets in the Real Estate Account to follow the instructions applicable to plans with assets in a Direct Filing Entity that does such a direct filing.