On behalf of TIAA-CREF Institutional Mutual Funds (the “Trust”), we are attaching for filing Post-Effective Amendment No. 26 to the above-captioned registration statement on Form N-1A (“Amendment No. 26”), including exhibits. The sole purpose of this filing is to add six new series of the Trust (the “New Funds”), including three new Lifecycle Funds (a sub-family of funds of the Trust). The disclosure herein is substantially similar to disclosure filed in the Trust’s Post-Effective Amendment No. 24, filed on September 14, 2007, which was reviewed by members of the Commission’s staff.

Amendment No. 26 is being filed pursuant to paragraph (b) of Rule 485 under the Securities Act of 1933 (“1933 Act”), and it is proposed to become effective on November 30, 2007. Pursuant to paragraph (b)(4) of Rule 485 under the 1933 Act, the undersigned represents that Amendment No. 26 does not contain disclosures that would render it ineligible to become effective pursuant to paragraph (b) of Rule 485.


	SEC COVER LETTER

Teachers Insurance and Annuity Association of America		Rachael M. Zufall
College Retirement Equities Fund		Senior Counsel
8500 Andrew Carnegie Blvd		(704) 988-4446
Charlotte, NC 28075		(704) 595-0946 FAX
		rzufall@tiaa-cref.org


	Re:	TIAA-CREF Institutional Mutual Funds
		Post-Effective Amendment No. 26 to Registration Statement
		on Form N-1A (File Nos. 333-76651 and 811-09301)


	Very truly yours,

	/s/ Rachael M. Zufall

	Rachael M. Zufall