EXHIBIT 14

TIAA AND TIAA-CREF FUNDSCODE OF ETHICSFORSENIOR FINANCIAL OFFICERS

Introduction

As noted in
TIAA-CREFs Code of Business Conduct:

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| | TIAA-CREF is
 committed to the highest level of legal, ethical, and moral standards in the
 conduct of our business. This extends to every action we take in working with
 participants, educational institutions, and other business or investment
 organizations. Moreover, upholding high standards in dealing with others
 requires that we, as associates, act ethically and responsibly among
 ourselves. At the heart of ethical conduct is a commitment to serve others
 fairly and well.
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| | The honesty,
 integrity and sound judgment of the principal executive officers, principal
 financial officers, principal accounting officers or controllers of TIAA and
 of the TIAA-CREF Funds (referred to herein collectively as the Senior
 Financial Officers) is fundamental to our reputation and success. Thus, in
 addition to complying with the Code of Business Conduct, each Senior
 Financial Officer is subject to this Code of Ethics.                                         

Specific Provisions

Conflicts
of Interest.Each Senior Finance Officer should avoid
actual or apparent conflicts of interest between personal and professional
relationships.

A
conflict of interest occurs when a Senior Financial Officers private
interest interferes with the interests of TIAA-CREF. For example, the Officer
should not cause TIAA-CREF to take action, or fail to take action, for the
personal benefit of the officer rather than the benefit of TIAA-CREF. Other
conflicts could occur from outside business activities that detract from an
individuals ability to devote appropriate time and attention to TIAA-CREF. Any
questions relating to potential conflict of interest situations should be discussed
with the General Counsel.

Complete
and Accurate Disclosures.Each Senior Financial
Officer is required to be familiar, and comply, with TIAA-CREFs disclosure
controls and procedures so that TIAA-CREFs documents filed with the SEC comply
in all material respects with the applicable federal securities laws. In
addition, each Senior Financial Officer having direct or supervisory authority
regarding SEC filings or TIAA-CREFs other public communications should, to the
extent appropriate within his or her area of responsibility, consult with other
TIAA-CREF officers and employees and take other appropriate steps regarding
these disclosures with the goal of making full, fair, accurate, timely and
understandable disclosure.

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| | Each Senior Financial
 Officer must:                             
| |                                                                   |                                                                                                                                                                                                                                                                                                     
| |                                                                  | Familiarize
 himself or herself with the disclosure requirements applicable to TIAA-CREF
 as well as the business and financial operations of TIAA-CREF;                                                                                                                                            
| |                                                                   |                                                                                                                                                                                                                                                                                                     
| |                                                                  | Not
 knowingly misrepresent, or cause others to misrepresent, facts about
 TIAA-CREF to others, whether within or outside TIAA-CREF, including to
 TIAA-CREFs internal auditors, independent Trustees, independent auditors,
 and to governmental regulators and self-regulatory organizations; and
| |                                                                   |                                                                                                                                                                                                                                                                                                     
| |                                                                  | Adhere to
 the standards and restrictions imposed by applicable laws, rules and
 regulations, including those relating to affiliated transactions, accounting
 and auditing matters.                                                                                                                
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| | Reporting and Accountability.Each Senior
 Financial Officer must:
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| |                                                                  | Upon receipt
 of this Code of Ethics, sign and submit to the General Counsel an
 acknowledgement stating that he or she has received, read, and understands
 the Code;                                                                                                                              
| |                                                                   |                                                                                                                                                                                                                                                                                                     
| |                                                                  | Annually
 thereafter submit a form to General Counsel confirming that he or she has
 received, read and understands the Code of Ethics and has complied with the
 requirements of the Code; and                                                                                                     
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| |                                                                  | Notify the
 General Counsel promptly if he or she becomes aware of any existing or
 potential violation of this Code. Failure to do so is itself a violation of
 this Code.                                                                                                                         

Except
as described otherwise below, the General Counsel is responsible for applying
this Code to specific situations and has the authority to interpret this Code
in any particular situation. The General Counsel shall take all action he considers
appropriate to investigate any actual or potential violations reported to him.

The
TIAA and TIAA-CREF Funds Audit Committees shall have the sole discretionary
authority to approve any deviation or waiver from this Code of Ethics for their
respective Senior Financial Officers. Any waiver, including an implicit waiver,
shall be promptly disclosed as required either through an SEC filing or through
a posting on TIAA-CREFs Internet website. Such disclosure shall include a
brief description of the nature of the waiver, the name of the person to whom
the waiver was granted, and the date of the waiver. For purposes of such
disclosure, the term waiver means the approval by the TIAA and TIAA-CREF
Funds Audit Committee(s) of a material departure from a provision of this Code
of Ethics, and the term implicit waiver means the Audit Committees failure
to take action within a reasonable period of time regarding a material
departure from a provision of this Code of Ethics.

TIAA-CREF
will promptly disclose any amendment to this Code of Ethics as required in
accordance with the SECs rules.

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