Must we attach an annual statement of assets and liabilities of a pooled separate account or a certification to our Form 5500 filing, as required by the instructions for Line 31 (c)(12)?
Yes. If your plan has any participants who have invested in the TIAA Real Estate Account during the plan year, you must meet this requirement because the account is a pooled separate account. However, instead of the attaching of an annual statement of assets and liabilities, which is available in the TIAA Real Estate prospectus, the attachment you can use can be downloaded from the Form 5500 Instruction Materials and is also included in the Form 5500 information package you receive from TIAA-CREF. TIAA files an annual financial statement for the TIAA Real Estate Account directly with the Department of Labor that meets this and the other DOL requirements for such a filing.
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