Code of Ethics

We have a fiduciary responsibility to our clients and we are keenly aware of it at all times.  It permeates everything we do.

INTEGRITY

Integrity is the most basic prerequisite to earning and retaining your trust.  We will uphold the very highest standards of integrity.  We will not compromise our principles for any reason.  Character is at least as important as competence in the financial services profession, possibly more so.

HONESTY

Honesty and openness are the keystones of the adviser-client relationship.  We will be truthful and candid with you.  We will never make a promise that we do not intend to keep.  We will not tell you what you want to hear if we believe it not to be true.  If we are unable to meet a commitment, we will inform you as such as early as possible and attempt to fairly renegotiate the terms of that commitment.

OBJECTIVITY

An adviser who has conflicts of interest is likely to give self-serving advice.  The most common such conflicts are the widespread practice of the adviser being compensated by commissions on products they sell to their clients.  In such a situation, one shouldn't be surprised that advisers (who act largely as salespeople) tend to recommend products which maximize their own commissions, rather than those which are in the best interests of the client (which typically are the ones with the lowest fees).

Independence and impartiality, therefore, are fundamental to any adviser who is serious about acting in good faith and in the best interest of the client.  We will endeavor to avoid conflicts of interest whenever possible.  We accept no soft dollar commissions.   We do not receive fees or compensation from any party based on the referral of a client or the client's business.  We prefer to be paid solely by our clients.  Our fees aren't dependent in any way on any client's purchase or sale of a financial product.  If we were paid by any external party (or by a client as the result of their purchase or redemption of a financial product), it would represent a potential (or actual) conflict of interest and would endanger our all-important objectivity (or, just as important, your perception of our objectivity).

COMPETENCE

We will endeavor to constantly increase our professional knowledge.  We continuously brainstorm for improved strategies which might better help you to realize your financial goals.  If we should believe that a strategy we previously recommended to you can be prudently improved, we aren't afraid to tell you so.  We back up our recommendations with detailed rationale in writing — if we can't convince you that a particular course of action is prudent, you shouldn't follow it.  Our advice is based on the best academic research and careful analysis, never a "hunch."

In addition to our own Code of Ethics, we are also committed to complying with the following standards:

The Certified Financial Planner (CFP) Board's Code of Ethics and Professional Responsibility.

Accredited Investment Fiduciary (AIF®) http://www.fi360.com/main/home.jsp?jsessionid=279661232737219905

The Financial Planning Association (FPA) Code of Ethics.

The Association for Investment Management and Research (AIMR) Code of Ethics and Standards of   Professional Conduct.

The Society of Financial Service Professionals (SFSP) Code of Professional Responsibility.