EXHIBIT 14

TIAA AND TIAA-CREF FUNDSCODE OF ETHICSFORSENIOR FINANCIAL OFFICERS

Introduction

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





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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- 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.

Reporting and Accountability.Each
    Senior Financial Officer must:

- 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
- 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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