AIF

Administrative Staff on

Paul Grant Truesdell, J.D., AIF, President & CEO

TrueStar Advisors, Inc.

A graduate of one of the first AIF graduate programs.

Accredited Investment Fiduciary® (AIF®) Designation training empowers investment professionals with the fiduciary knowledge and tools they need to serve their clients’ best interests. The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential.

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Fi360 Designee Code of Ethics

I recognize that this Code of Ethics, and its principles and obligations, are in addition to those set forth by any other Code that governs my professional and ethical conduct.

To my clients, I will:

Employ and provide the client information on the Prudent Practices when serving as an investment fiduciary and/or advising other investment fiduciaries. Act with honesty and integrity and avoid conflicts of interest, real or perceived. Ensure the timely and understandable disclosure of relevant information that is accurate, complete, and objective. Be responsible when determining the value of my services and my form of compensation; taking into consideration the time, skill, experience, and special circumstances involved in providing my services. Know the limits of my expertise, and refer my clients to colleagues and/or other professionals in connection with issues beyond my knowledge and skills. Respect the confidentiality of information acquired in the course of my work, and not disclose such information to others, except when authorized or otherwise legally obligated to do so. I will not use confidential information acquired in the course of my work for my personal advantage. Not exploit any relationship or responsibility that has been entrusted to me. To my community (whether defined by work, family, and/or friends), I will:

Proactively promote and be a steward of ethical behavior as a responsible partner among my peers in the work environment and in my community. Ensure that the overall promotion of my practice is implemented in the best interests of my profession. Seek, accept, and offer honest criticism of technical work; acknowledge and correct errors; and properly credit the contributions of others. Use corporate assets and resources employed or entrusted to me in a responsible manner. Continue to improve my knowledge and skills, share ideas and information with colleagues, and assist them in their professional development.

Conduct Standards

The Conduct Standards pertain to criminal and civil litigation, regulatory events, and personal and professional conduct. Self-disclosure of such events is required when applying for the AIF®, AIFA®, or PPC® designation, as is ongoing disclosure.

Each candidate for a Designation (or Designee) must meet the following conduct standards.

Status Standards No candidate for a Designation (or Designation holder) may be any of the following:

Felon A person who, within the last 10 years, has been convicted of, or against whom a guilty plea has been entered with respect to, a felony under the criminal laws of the United States, any State, or any foreign jurisdiction.

Financial Criminal / Civil Defendant A person who, within the last ten (10) years, has been convicted of, or against whom a guilty plea has been entered with respect to, a crime other than a felony, or is the subject of an administrative or enforcement order by a financial regulatory agency, or has been a non-prevailing defendant in a civil or criminal cause of action, per guidelines below, which in any of the above cases involves misrepresentation, fraud, extortion, conversion, misappropriation, fiduciary breach, theft, or other similar violation of the laws or any administrative rules of the United States, any State, or any foreign jurisdiction.

Suspended from the investment profession A person who, within the last two (2) years, has been barred or suspended, as to any form of activity, as a disciplinary measure from registration under the securities laws or regulations (or similar laws or regulations relating to the investment process) of the United States, any State, or any foreign jurisdiction, or from association or affiliation with a self-regulatory organization with legal authority over the investment process.

Violations A candidate for a Designation (or Designation holder) who commits any of the following acts or omissions may be subject to sanctions:

False or misleading statement Intentionally or recklessly makes a misleading statement or omission with respect to a candidate’s application for a Designation, a Designation holder’s application for renewal, or during an investigation of a Designation holder’s satisfaction of these standards.

Failure to respond or cooperate Fails to respond to any request for information or otherwise failing to cooperate in any investigation of a candidate’s or Designation holder’s satisfaction of these standards.

Failure to report pending action Fails to expeditiously report any violation of the status standards, or any decision by a court, regulatory agency, or administrative agency that is likely to evidence that the Designation holder engaged in unprofessional conduct.

Bankruptcy Filed for, or been forced into, bankruptcy due to failure of a financial services related business during the last five (5) years.

Code of Ethics Violates or fails to satisfy the Code of Ethics.

Unprofessional Conduct Engages in unprofessional conduct, which may include without limitation (a) any act or omission that results in a civil finding by a court of competent jurisdiction or by arbitration of a fiduciary breach by the candidate or Designation holder within the last ten (10) years, (b) any act or omission that results in the divestiture or revocation of a professional designation or license or other reprimand relating to fiduciary conduct, (c) any censure by an administrative agency relating to fiduciary conduct within the last ten (10) years, (d) any negligent, false, or misleading statement or omission with respect to a candidate’s application for a Designation or during an investigation of a Designation holder’s satisfaction of these standards, (e) any failure of a Designation holder to report to the Center for Fiduciary Studies the Designation holder’s violation of these Conduct Standards, or (f) any conduct unbecoming of a Designation holder or discrediting the Designation.

Note

Mr. Truesdell also holds a CLU, ChFC, and RFC, has over three decades of unblemished experience in the financial services industry, serves as an expert witness in insurance and securities cases for individual and class actions, and is a subject matter expert in the area of estate planning and Smart Beta (Equal Weight) investment managment process-based investing.