CODE OF ETHICS

The relationship between the Exchange Accommodator and the Exchanger requires a high level of confidence in that the client entrusts and deposits with the Accommodator title to real estate and proceeds from the sale of real estate in furthering an I.R.C. §1031 exchange. Therefore, it is the duty of the Exchange Accommodator to uphold and improve the standards of its profession and to share the responsibility for its integrity and honor.

Each member of the Federation of Exchange Accommodators pledges to observe the letter and spirit of this Code of Ethics and to conduct its business in accordance with it.

ARTICLE I

An Exchange Accommodator shall keep informed of laws, regulations, and legislation which affects I.R.C. §1031 exchanges and the Accommodator profession.

ARTICLE II

Protection of the public against fraud, misrepresentation, and other illegal practices in the Exchange Accommodator profession shall be the responsibility of each Accommodator. An Exchange Accommodator shall not voluntarily participate in any act which it knows to be unlawful or against the standard of conduct set forth in this Code, even if directed to do so by the Exchanger or his agent or advisor. It shall be the duty of every Exchange Accommodator to protect the reputation of the profession by exposing those engaged in such practices.

ARTICLE III

It is the duty of an Exchange Accommodator to act in such a manner as to preserve the trust and confidence of its clients. Without the written consent of the Exchanger, an Exchange Accommodator shall not reveal the contents of any file to any party not entitled except in case of a subpoena being presented

ARTICLE IV

An Exchange Accommodator who is not licensed to practice law or accountancy shall not engage in activities which constitute such practice. The Exchange Accommodator shall recommend in all cases that the parties involved in an exchange transaction seek legal counsel and accounting advice.

ARTICLE V

An Exchange Accommodator shall not accept any remuneration paid directly or indirectly by the client without the client's knowledge and consent. If recommending other products or services, they shall disclose to the client any financial benefits or fees the Exchange Accommodator may receive as a result of such recommendation. They shall not recommend or suggest to a client the use of services of another organization or business entity in which they have a direct interest without disclosure of such interest at the time of recommendation or suggestion. At no time shall an Exchange Accommodator accept any illegal payment of any kind.

It is the duty of an Exchange Accommodator to disclose to its clients those circumstances, relationships, and interests, if any, which might adversely influence the client in the selection of an Exchange Accommodator. This disclosure shall be made when the influencing factor becomes known to the Exchange Accommodator.

ARTICLE VI

An Exchange Accommodator shall act in the best interest of its clients by providing and following written exchange agreements and assignment documents, by provided (when asked) copies of all documents received from escrow to its clients and their representatives, and by acting in a timely manner in order to expedite the transfer and minimize the time taken by the exchange.

ARTICLE VII

An Exchange Accommodator shall act in the best interest of its clients. This shall include (but not be limited to) the duty to: keep the exchange proceeds in a stable financial institution or other reliable investment program unless the client requests a specific investment; provide financial information to the client and his representatives during the Exchange Period as requested; and give a full accounting of funds to which the client is entitled at the end of the exchange.

ARTICLE VIII

An Exchange Accommodator shall cooperate fully with other Accommodators in all matters affecting the industry as a whole. This includes, but is not limited to, the sharing of knowledge and experience through active participation in FEA educational programs, reporting violations of the Code of Ethics to the President of the FEA in writing, and active participation in the FEA.

ARTICLE IX

Except in the case of disclosure of conduct in violation of the Code of Ethics, or in the case of potential civil litigation the Exchange Accommodator shall never denigrate nor disparage the professional practices of a competitor nor volunteer an opinion of a competitor's transactions or business practices.

ARTICLE X

An Exchange Accommodator shall maintain, uphold and conform to this Code of Ethics and the rules, regulations, and By-Laws of the Federation, shall at all times positively reflect the professional standards of practice set forth herein, and shall take an active part in the work of the Federation.

ENFORCEMENT

The penalty for failure to meet the standards of this Code of Ethics shall be private reprimand by, public reprimand by, suspension of membership in, or expulsion from the Federation of Exchange Accommodators. The procedure for implementation of the penalty phase shall be:

1. The Complainant shall submit to the President of FEA a written complaint specifically describing in as much detail as possible the violation.
2. The President shall appoint a three person board of review to consider the violation and recommend the action to be taken. At its option, the board of review may solicit testimony in oral or written form.
3. The recommended action will be submitted to the Accused with copies to the Complainant and the President.
4. If no action is taken by the Accused, the recommended action shall stand. The Accused shall have forty-five days from mailing of the notice to his last known address to request a public hearing from the President which shall be scheduled within forty-five days of the receipt of the request by agreement of the parties. Written and oral testimony may be received and argument made and a written decision submitted to the Accused within fifteen days of the hearing.
5. The decision may be appealed to the next annual meeting.
6. If the Accused continues to claim an association with the FEA after suspension or expulsion, the FEA Board of Directors may, at its option, release to the public the information causing the suspension or expulsion.