EXHIBIT 14

                            TIAA AND TIAA-CREF FUNDS
                                 CODE OF ETHICS
                                       FOR
                            SENIOR FINANCIAL OFFICERS

INTRODUCTION

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

      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.

      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.

<PAGE>

      Each Senior Financial Officer must:

      o     Familiarize himself or herself with the disclosure requirements
            applicable to TIAA-CREF as well as the business and financial
            operations of TIAA-CREF;

      o     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

      o     Adhere to the standards and restrictions imposed by applicable laws,
            rules and regulations, including those relating to affiliated
            transactions, accounting and auditing matters.

      REPORTING AND ACCOUNTABILITY. Each Senior Financial Officer must:

      o     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;

      o     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

      o     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.