SEC Division of Investment Management staff letter: College Retirement Equities Fund (CREF)

The College Retirement Equities Fund (CREF) requests assurance that the SEC staff will not recommend enforcement action if its Money Market Account uses the amortized cost method to value all portfolio securities without maintaining a constant price per share. CREF argues that its single-tier structure and policy of not distributing dividends make it impossible to maintain a stable net asset value, yet it will comply with all other Rule 2a-7 requirements, including shadow pricing procedures with a one percent deviation trigger. The fund intends to implement this valuation change no later than May 1, 2009.

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1775 I Street, N.W.
Washington. DC 20006-2401 Dechert '+'1 202 261 3300 Main '+'1 202 261 3333 Fax LlP www.dechert.com RUTH S. EPSTEIN ruth.epsteln@dechert.com '+'1 (202) 261·3322 Direct +1 (202) 281·3022 Fax April 13, 2009 Robert E. Plaze, Esq.

Associate Director

Division ofInvestment Management

U.S. Securities and Exchange Commission

100 F Street, N.W.

Washington, D.C. 20549

Re: Request for No-Action Assurance under Section 2(a)(41) ofthe

Investment Company Act of 1940 and Rules 2a-4, 2a-7. and 22c-l thereunder

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