TIAA-CREF Trust Company, FSB,

On June 28, 2013, the Office of the Comptroller of the Currency issued a Consent Cease and Desist Order to TIAA-CREF Trust Company, FSB, St. Louis, Missouri (Bank).

The Bank is a federally chartered savings bank with its only office located in St. Louis, Missouri. Its FDIC-reported financials for March 31, 2013, show a 236% growth in total assets over March 31, 2012 ($681 million to $2287 million), and a growth in staffing from 74 to 105 FTEs. The company was established in 1998.

The C&D Order has several articles requiring the bank's board to ensure it has competent management, a viable strategic plan, a capital plan, and improved management of its liquidity, funding concentration, interest rate risk and information security. Several articles, however, focus on BSA/AML concerns, requiring the bank to develop of put into place—

1. a comprehensive BSA action plan
2. a BSA risk assessment
3. BSA independent testing
4. BSA internal controls and high risk identification
5. CDD and EDD information gathering
6. a written program to ensure compliance with SAR filing requirements
7. BSA training
8. appropriate BSA compliance department staffing