TIAA Real Estate Account c/o Teachers Insurance and Annuity Association of America 8500 Andrew Carnegie Boulevard Charlotte, NC 28262 F. Scott Thomas Senior Director and Associate General Counsel (704) 988-3687 (tele) sthomas@tiaa.org

April 26, 2019

VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-4644

Mail Stop 3233

Attention: Sara von Althann, Staff Attorney

Re: TIAA Real Estate Account Amendment No. 1 to the Registration Statement on Form S-1 (File No. 333-230322)

Ladies and Gentlemen:

On behalf of the TIAA Real Estate Account (the “Account”), we have attached for filing Pre-Effective Amendment No. 1 to the above-captioned registration statement on Form S-1 (“Amendment No. 1”), including exhibits.

Amendment No. 1 is being filed pursuant to Rule 429 under the Securities Act of 1933 (“1933 Act”), and it is proposed to become effective as soon as reasonably practicable by 9:00 a.m. EDT on April 30, 2019. Pursuant to Rule 429 under the 1933 Act, the undersigned represents that Amendment No. 1 does not contain disclosures that would render it ineligible to become effective pursuant to Rule 429.

The main purpose of Amendment No. 1 is to update certain disclosure in the Account’s prospectus, including financial and performance information.

If you have any question regarding this filing, please do not hesitate to call me at (704) 988-3687.

Sincerely,

/s/ F. Scott Thomas

F. Scott Thomas

Senior Director and Associate General Counsel

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