Does CREF hold the plans investment assets and execute investment transactions on behalf of the plan?
No. The underlying assets of CREF accounts are not plan assets. CREF is an investment company registered under the Investment Company Act of 1940. Under ERISA Section 401(b)(1), the underlying assets of an investment company are not plan assets, though the securities issued by such investment companies are plan assets. As a result, CREF units are plan assets, but the underlying assets of the CREF accounts are not. It is the value of the CREF units that must be reported on schedule H or schedule I, and not the value of the assets underlying the accounts.
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