TIAA CREF Deemed Loan Reporting Issue

Curious to see if people are seeing the same thing as me with TIAA CREF.  I swear they are doing loan reporting for participant loans (NOT Plan Loans--if you work with TIAA you know there is a distinction) the wrong way.  As far as I can tell this is what they are doing:

1) Including deemed distributed loans in the ending balance of participant loans

2) Reporting loan offsets as deemed distributions.  Loan offsets of course should be included in the regular distribution item. 

I hope I'm wrong, but honest to goodness I'm pretty certain they are messing it up. And you would never know it unless you really dig (I did not because I had faith in TIAA, but the auditor is digging, and by golly I think they are correct).