Gresham Investment Management Llc

Allegations: ALLEGED VIOLATIONS OF VARIOUS PROVISIONS OF NEW YORK INSURANCE LAWS Status: Final Sanction Detail: ON MARCH 17, 2016, TIAA ENTERED INTO A STIPULATION WITH THE NEW YORK DEPARTMENT OF FINANCIAL SERVICES ("NYDFS") TO, AMONG OTHER THINGS, FINDINGS BY NYDFS THAT TIAA VIOLATED VARIOUS PROVISIONS OF NEW YORK INSURANCE LAW. THE STIPULATION CITED VIOLATIONS OF NYDFS REGULATION 60 AND REGULATION 152 RELATED TO REPLACEMENT AND RECORDKEEPING REQUIREMENTS. TIAA PAID A CIVIL PENALTY IN THE AMOUNT OF $18,112. THE STIPULATION COVERED THE EXAM PERIOD 01/2005 THROUGH 12/2008. NYDFS HAS ASSESSED THE REMEDIATION PLAN DURING THE SUBSEQUENT EXAMINATION IN 2013 WITH NO FINDINGS OR VIOLATIONS IDENTIFIED RELATED TO REPLACEMENT, ILLUSTRATION, DISCLOSURE AND RECORDKEEPING REQUIREMENTS. Summary: THIS MATTER DOES NOT INVOLVE GRESHAM INVESTMENT MANAGEMENT LLC OR NUVEEN

Allegations: ALLEGED VIOLATIONS OF VARIOUS PROVISIONS OF CONNECTICUT INSURANCE LAWS Status: Final Sanction Detail: IN 2014, THE CONNECTICUT INSURANCE DEPARTMENT (CID) REVIEWED TEACHERS INSURANCE AND ANNUITY ASSOCIATION OF AMERICA (TIAA) RECORDS OF LICENSED /APPOINTED PRODUCERS AND INSURANCE DEPARTMENT RECORDS AND IDENTIFIED ONE (1) INDIVIDUAL EMPLOYEE WHO DID NOT HAVE AN APPOINTMENT WITH TIAA IN ACCORDANCE WITH CONNECTICUT STATE REQUIREMENTS. THE CID CONCLUDED THAT THE CONDUCT VIOLATED SECTION 38A-702M OF THE CONNECTICUT GENERAL STATUTES AND IMPOSED A FINE OR ADMINISTRATIVE FINE ON TIAA FOR THE VIOLATION IN THE AMOUNT OF $1,500 PURSUANT TO SECTIONS 38A-2, 38A-41 AND 38A-817 FOR THE CONNECTICUT GENERAL STATUTES. Summary: THIS MATTER DOES NOT INVOLVE GRESHAM INVESTMENT MANAGEMENT LLC OR NUVEEN.

Allegations: THE ALLEGED VIOLATIONS INCLUDED THE FOLLOWING: FAILURE TO PROVIDE THE "NOTICE OF AVAILABILITY OF THE DEPARTMENT OF INSURANCE" AND FAILURE TO PROVIDE BENEFICIARIES WITH A REASONABLE WRITTEN EXPLANATION OF DELAY OF CLAIM PAYMENT BEYOND 45 DAYS, AS REQUIRED BY SECTION 50 ILL. ADM. CODE 919.70(A)(2); AND FAILURE TO NOTIFY BENEFICIARIES OF THE AVAILABILITY OF INTEREST AT THE TIME OF CLAIM SUBMISSION, AS REQUIRED BY 215 ILCS 5/224(1)(I). Status: Final Sanction Detail: ON MARCH 2, 2020, THE ILLINOIS DEPARTMENT OF INSURANCE (IDI) ISSUED A MARKET CONDUCT EXAMINATION VERIFIED REPORT AND STIPULATION AND CONSENT ORDER IN CONNECTION WITH A MARKET CONDUCT EXAMINATION OF TEACHERS INSURANCE AND ANNUITY ASSOCIATION OF AMERICA ("TIAA"). WITHOUT ADMITTING FAULT, LIABILITY, OR WRONGDOING, TIAA AGREED TO A STIPULATION AND CONSENT ORDER (THE "CONSENT ORDER") FINDING THAT IT VIOLATED SECTIONS 50 ILL. ADM. CODE 919.70(A)(2) FOR NOT PROVIDING A "NOTICE OF AVAILABILITY OF THE DEPARTMENT OF INSURANCE" AND FOR NOT PROVIDING BENEFICIARIES WITH A REASONABLE WRITTEN EXPLANATION OF DELAY OF CLAIM PAYMENT BEYOND 45 DAYS; AND VIOLATED 215 ILCS 5/224(1)(I) FOR NOT NOTIFYING BENEFICIARIES OF THE AVAILABILITY OF INTEREST AT THE TIME OF CLAIM SUBMISSION. THE IDI IMPOSED A CIVIL FORFEITURE OF $18,000 FOR TIAA. Summary: THIS MATTER DOES NOT INVOLVE TEACHERS ADVISORS, LLC OR NUVEEN, LLC.