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Code of Ethics


A.    Fiduciary Duty. This Code of Ethics is based on the principle that all employees of Future

Benefits, Inc. (“the Company”) have a fiduciary duty to place theinterest of clients ahead of their own and the Company's.  This Code of Ethics applies to all"Access Persons" (defined below). Access Persons must avoid activities, interests and relationships thatmight interfere with making decisions in the best interests of the Company'sAdvisory Clients. 


For purposes ofthis policy, the following words shall mean:


"Access Persons" means all employees, directors,officers, or members of the Company, as the case may be, who (i) have access tononpublic information regarding Advisory Clients' purchases or sales ofsecurities, (ii) are involved in making securities recommendations to AdvisoryClients or (iii) have access to nonpublic recommendations or the portfolioholdings of a Client. Client services personnel who regularly communicate withAdvisory Clients also may be deemed to be Access Persons.     


"Advisory Client" means any account for which theCompany serves as investment adviser, renders investment advice or makesinvestment decisions. 


"Code" means this policy as supplemented by otherpolicies and procedures contained in the Company's Compliance Manual.


"Reportable Securities" means all securities in which anAccess Person has a beneficial interest except: (i) U.S. Government securities, (ii) money market instruments (e.g.,bankers' acceptances, bank certificates of deposit, commercial paper,repurchase agreements and other high quality short-term debt instruments),(iii) shares of money market funds, (iv) shares and holding in other mutualfunds unless the Company acts as the investment advisor to, or the principalunderwriter of, the subject fund, and (iv) units of a unit investment trust ifthe UIT is invested exclusively in unaffiliated mutual funds.


 As fiduciaries, all Access Persons must at alltimes:


1. Place the interests of Advisory Clients first.  All Access Persons must avoid serving theirown personal interests ahead of the interests of the Company's Advisory Clients.  Access Persons may not induce or cause anAdvisory Client to take action, or not to take action, for personal benefit,rather than for the benefit of the Advisory Client.  For example, a supervisor or employee wouldviolate the policy by causing an Advisory Client to purchase a security he orshe owned for the purpose of increasing the price of that security.


2. Avoid taking inappropriate advantage of their position.  The receipt of investment opportunities,perquisites or gifts from persons seeking business with the Company or itsAdvisory Clients, could call into question the exercise of the independentjudgment of an Access Person.  AccessPersons may not, for example, use their knowledge of portfolio transactions toprofit by the market effect of such transactions. 


3. Conduct all personal securities transactions in fullcompliance with this Code including both pre-clearance and reportingrequirements.  Doubtfulsituations always should be resolved in favor of Advisory Clients.  Technically compliance with the Code'sprovisions shall not automatically insulate from scrutiny any securitiestransactions or actions that indicate a violation of the Company's fiduciaryduties. 


B.  Appendices to the Code.  The Code shall be supplemented by theCompany’s Compliance Manual in its entirety, specifically including, withoutlimitation, the following Sections, each of which is specifically included inthe Code as an Appendix.


1.          Privacy;


2.          PrincipalTrading;


3.          Trading (andProhibited Transactions);


4.          PersonalSecurities Transactions & Records; and


5.          Insider Trading.


6.          AnnualCertification of Compliance with the Company’s Code of Ethics


C.  Conduct andCompliance with Laws.  This code isintended to comply with the various 

provisions of the Advisers Act and also requires that allsupervised persons comply with the various applicable provisions of the InvestmentCompany Act of 1940, as amended, the Securities Act of 1933, as amended, theSecurities Exchange Act of 1934, as amended, and applicable rules andregulations adopted by the Securities and Exchange Commission (“SEC”).


Section 204A of the Advisers Act requires the establishment andenforcement of policies and procedures reasonably designed to prevent themisuse of material, nonpublic information by Investment advisers.  Such policies and procedures are contained inthis Code.  The Code also containspolicies and procedures with respect to personal securities transactions of allFuture Benefits, Inc. supervised persons as defined herein.  These procedures cover transactions in areportable security in which a supervised person has a beneficial interest inor accounts over which the supervised person exercises control as well astransactions by members of the supervised person’s immediate family.


Section 206 of the Advisers Act makes it unlawful for FutureBenefits, Inc. or its agents or employees to employ any device, scheme orartifice to defraud any client or prospective client, or to engage infraudulent, deceptive or manipulative practices.  This Code contains provisions that prohibitthese and other enumerated activities and that are reasonably designed todetect and prevent violations of the Code, the Advisers Act and rulesthereunder.


D.  Personal Securities Trading.  All “access persons” (as defined previously)must report their personal securities transactions and holdings on a monthlybasis to the Chief Compliance Officer. See Appendix 4 for the actual Policies and Procedures to befollowed.  All reviews of transactionsand holdings must be initialed and dated.


E.  Copy of Code and Annual Certification.  Future Benefits, Inc. shall provide a copy ofthe                                                     

code of ethics to each of its supervised persons.  The copy shall be in the form of anelectronic document on each supervised person’s computer desktop.  Each supervised person shall certifycompliance of this code annually (See Appendix 6).


F.   Pre-Clearance Required for Participation inIPOs or Limited Offering.  No access

person shall acquire anybeneficial ownership in any securities in Initial Public Offering or LimitedOffering for his or her account without the prior written approval of the ChiefCompliance Officer who has been provided with full details of the proposedtransaction (including written certification that the investment opportunitydid not arise by virtue of the access person’s activities on behalf of aclient) and, if approved, will be subject to continuous monitoring for possiblefuture conflicts.





A.  Confidentiality.  Access Persons are prohibited from revealinginformation relating to the investment intentions, activities or portfolios ofAdvisory Clients except to person whose responsibilities require knowledge ofthe information.


B.  Gifts.  The following provisions on gifts apply toAccess Persons:


1.  Accepting Gifts.  On occasion, because of their position withthe Company, Access Persons may be offered, or may receive without notice,gifts from clients, brokers, vendors or other persons.  Acceptance of extraordinary or extravagantgifts is prohibited.  Any such gifts mustbe declined and returned in order to protect the reputation and integrity ofthe Company.  Gifts of nominal value (i.e.,a gift whose reasonable value, alone or in the aggregate, is not more than $100in any twelve month period), customary business meals, entertainment (e.g.,sporting events), and promotional items (i.e., pens, mugs, T-shirts) may beaccepted.  All gifts received by anAccess Person that might violate this Code must be promptly reported to theChief Compliance Officer (“CCO”). 

2.  Solicitation of gifts.  Access Persons are prohibited from solicitinggifts of any size under any circumstances.

3.  Giving gifts.  Access Persons may not give any gift with avalue in excess of $100 (per year) to an Advisory Client or persons who dobusiness with, regulate, advise or render professional services to the Company.

C.  Company Opportunities.  Access Persons may not take personaladvantage of any opportunity properly belonging to any Advisory Client or theCompany.  This includes, but is notlimited to, acquiring Reportable Securities for one's own account that wouldotherwise be acquired for an Advisory Client.

D. Undue Influence. Access Persons shall not cause or attempt to cause any Advisory Clientto purchase, sell or hold any security in a manner calculated to create anypersonal benefit to such Access Person. If an Access Person stands to materially benefit from an investmentdecision for an Advisory Client that the Access Person is recommending, theAccess Person must disclose to the Chief Compliance Officer the full nature ofthe beneficial interest that the Access Person has in that security, anyderivative security of that security or the security issuer, where the decisioncould create a material benefit to the Access Person or the appearance ofimpropriety.  The Chief ComplianceOfficer must determine whether or not the Access Person will be restricted inmaking investment decisions in respect of the subject security. 

E.  Reporting, Review andRecordkeeping.  All violations ofthe Code must be reported promptly to the CCO. The CCO shall periodically review Access Persons' personal tradingreports and otherwise take reasonable steps to monitor compliance with, andenforce, this Code of Ethics.  The CCOshall maintain in the Company's files (i) a current copy of the Code, (ii)records of violations and actions taken as a result of the violations, (iii)copies of all Access Persons' written acknowledgement of receipt of the Code,(iv) copies of the quarterly and annual compliance certificates required by theCode.   

F.  Sanctions.  If the CCO determines that a Access Personhas committed a  violation of the Code,the Company may impose sanctions and take other actions as it deemsappropriate, including a letter of caution or warning, suspension of personaltrading privileges, suspension or termination of employment, fine, civilreferral to the SEC and, in certain cases, criminal referral.  The Company also may require the offendingAccess Person to reverse the trades in question, forfeit any profit or absorbany loss derived therefrom and such forfeiture shall be disposed of in a mannerthat shall be determined by the Company in its sole discretion.  Failure to timely abide by directions toreverse a trade or forfeit profits may result in the imposition of additionalsanctions.

G.  Exceptions.  Exceptions to the Code will rarely, if ever,be granted.  However, the CCO may grantan occasional exception on a case-by-case basis when the proposed conductinvolves negligible opportunities for abuse. All exceptions shall be solicited and issued in writing.  No reports shall be required under this Codefor (i) transactions effected pursuant to an automatic investment plan and (ii)securities held in accounts over which the Access Person has no direct control.

H.  Compliance Certification.  All Access Persons shall sign a certificatepromptly upon becoming employed or otherwise associated with the Company thatevidences his or her receipt of this Code of Ethics and submit a completereport of the Access Person's securities holdings.  All Access Persons shall submit to the CCO,no later than 30 days after the close of each quarter, in the form proscribedby the Company for this purpose, a list of all personal transactions inReportable Securities.  During the monthof January, all Access Persons will be required to certify on the AnnualCertification of Compliance with the Code of Ethics form attached to this Codeas Appendix 6.


Dated:         03/15/2012            









1.      Privacy………………………………………………….Page 6




2.  Principal Trading ……………………………………….Page 9




3.     Trading/Prohibited Transactions……………………….Page 10




4.        PersonalSecurities Transactions & Records ...…….…...Page 13



5.   Insider Trading …………………………………………Page 15



6.      Annual Certification of Compliance with The

Company’s Codeof Ethics..……………………………Page 17

























      As a registered investment adviser,Future Benefits, Inc. must comply with SEC Regulation S-P (or other applicableregulations), which requires registered advisers to adopt policies andprocedures to protect the “nonpublic personal information” of natural personconsumers and customers and to disclose to such persons policies and proceduresfor protecting that information. Nonpublic personal information includes nonpublic “personallyidentifiable financial information” plus any list, description or grouping ofcustomers that is derived from nonpublic personally identifiable financialinformation.  Such information mayinclude personal financial and account information, information relating toservices performed for or transactions entered into on behalf of clients,advice provided by Future Benefits, Inc. to clients, and data or analysesderived from such nonpublic personal information.  Future Benefits, Inc. must also comply withthe California Financial Information Privacy Act (SB1) if the firm doesbusiness with California consumers.




      The purpose of these privacy policies andprocedures is to provide administrative, technical and physical safeguardswhich assist employees in maintaining the confidentiality of nonpublic personalinformation collected from the consumers and customers of an investmentadviser.  All nonpublic information,whether relating to an adviser’s current or former clients, is subject to theseprivacy policies and procedures.  Anydoubts about the confidentiality of client information must be resolved infavor of confidentiality.




      Thomas R. Hiten, the Chief ComplianceOfficer, is responsible for reviewing, maintaining and enforcing these policiesand procedures to ensure meeting Future Benefits, Inc.’s client privacy goalsand objectives while at a minimum ensuring compliance with applicable federaland state laws and regulations.  ThomasR. Hiten may recommend to the President any disciplinary or other action asappropriate.  Thomas R. Hiten is alsoresponsible for distributing these policies and procedures to employees and forconducting appropriate employee training to ensure employee adherence to thesepolicies and procedures.




      Future Benefits, Inc. has adopted variousprocedures to implement the firm’s policy and reviews to monitor and insure thefirm’s policy is observed, implemented properly and amended or updated, asappropriate, which include the following:


Non-Disclosure of Client Information


      Future Benefits, Inc. maintainssafeguards to comply with federal and state standards to guard each client’snonpublic personal information.  FutureBenefits, Inc. does not share any nonpublic personal information with anynonaffiliated third parties, except in the following circumstances:


·       As necessary to provide the service that theclient has requested or authorized, or to maintain and service the client’s account;

·       As required by regulatory authorities or lawenforcement officials who have jurisdiction over Future Benefits, Inc., or asotherwise required by an applicable law; and

·       To the extent reasonably necessary to preventfraud and unauthorized transactions.


      Employees are prohibited, either duringor after termination of their employment, from disclosing nonpublic personalinformation to any person or entity outside Future Benefits, Inc., includingfamily members, except under the circumstances described above.  An employee is permitted to disclosenonpublic personal information only to such other employees who need to haveaccess to such information to deliver our services to the client.


Security of Client Information


      Future Benefits, Inc. restricts access tononpublic personal information to those employees who need to know suchinformation to provide services to our clients.


      Any employee who is authorized to haveaccess to nonpublic personal information is required to keep such informationin a secure compartment or receptacle on a daily basis as of the close ofbusiness each day.  All electronic orcomputer files containing such information shall be password secured andfirewall protected from access by unauthorized persons.  Any conversations involving nonpublicpersonal information, if appropriate at all, must be conducted by employees inprivate, and care must be taken to avoid any unauthorized persons overhearingor intercepting such conversations.




Privacy Notices


      Future Benefits, Inc. will provide eachnatural person client with initial notice of the firm’s current policy when theclient relationship is established. Future Benefits, Inc. shall also provide each such client with a newnotice of the firm’s current privacy policies at least annually.  If Future Benefits, Inc. shares nonpublicpersonal information relating to a Californiaconsumer with an affiliated company under circumstances not covered by anexception under SB1, the firm will deliver to each affected consumer anopportunity to opt out of such information sharing.  If, at any time, Future Benefits, Inc. adoptsmaterial changes to its privacy policies, the firm shall provide each suchclient with a revised notice reflecting the new privacy policies.  The Chief Compliance Officer is responsiblefor ensuring that required notices are distributed to the Future Benefits,Inc.’s consumers and customers.













      Future Benefits, Inc.’s policy andpractice is to NOT engage in any principal transactions, and our firm’s policyis appropriately disclosed.




      Principaltransactions are generally defined as transactions where an adviser, acting asprincipal for its own account or the account of an affiliated broker-dealer,buys from or sells any security to any advisory client.  As a fiduciary and under the anti-fraudsection of the Advisers Act, principal transactions by advisers are prohibitedunless the adviser 1) discloses its principal capacity in writing to the clientin the transaction and 2) obtains the client’s consent to each principaltransaction before the settlement of the transaction




      Thomas R. Hiten, the Chief ComplianceOfficer, has the responsibility for implementing and monitoring our principaltrading policy and disclosures that the firm/affiliated firm does not engage inany principal transactions with advisory clients.




      Future Benefits, Inc. has adopted variousprocedures to implement the firm’s policy and reviews to monitor and insurethat the firm’s policy is observed, implemented properly and amended orupdated, as appropriate, which include the following:


  • Future Benefits, Inc.’s policy of prohibiting any principal trades with advisory clients has been communicated to relevant individuals in the Firm.
  • The firm’s policy is appropriately disclosed in the firm’s Form ADV/Disclosure Document.
  • Thomas R. Hiten, the Chief Compliance Officer, periodically monitors the firm’s advisory services and trading practices to help insure no principal trades occur for advisory clients.













      As an adviser and a fiduciary to ourclients, our clients’ interests must always be placed first and foremost, andour trading practices and procedures prohibit unfair trading practices and seekto disclose and avoid any actual or potential conflicts of interests or resolvesuch conflicts in the client’s favor.


      Our firm has adopted the followingpolicies and practices to meet the firm’s fiduciary responsibilities and toinsure our trading practices are fair to all clients and that no client oraccount is advantaged or disadvantaged over any other.


      Also, Future Benefits, Inc.’s tradingpractices are generally disclosed in our Disclosure Document provided toprospective clients and annually offered to clients.




      As a fiduciary, many conflicts ofinterest may arise in the trading activities on behalf of our clients, our firmand our employees, and must be disclosed and resolved in the interests of theclients.  In addition, securities laws,insider trading prohibitions and the Advisers Act, and rules thereunder,prohibit certain types of trading activities.




      The aggregation or blocking of clienttransactions allows an adviser to execute transactions in a more timely,equitable, and efficient manner and seeks to reduce overall commission chargesto clients.


      Because of the nature of our business(mostly mutual funds), Future Benefits does not aggregate trades.




      As a matter of policy, an adviser’sallocation procedures must be fair and equitable to all clients with noparticular group or client(s) being favored or disfavored over any otherclients.




      Future Benefits, Inc.’s policy prohibitsany allocation of trades in a manner that Future Benefits, Inc.’s proprietaryaccounts, affiliated accounts, or any particular client(s) or group of clientsreceive more favorable treatment than other client accounts.


      Future Benefits, Inc. has adopted a clearwritten policy for the fair and equitable allocation of transactions, (e.g.,pro-rata allocation, rotational allocation, or other means) which is disclosedin Future Benefits, Inc.’s Disclosure Document.




      Initial public offerings (“IPOs”) areofferings of securities which frequently are of limited size and limitedavailability.  IPOs may also become “hotissues” which are offerings that trade at a premium above the initial offeringprice.


      In the event Future Benefits, Inc.participates in any IPOs, Future Benefits, Inc.’s policy and practice is toallocate IPO shares fairly and equitably among our advisory clients accordingto a specific and consistent basis so as not to advantage any firm, personal orrelated account and so as not to favor or disfavor any client, or group ofclients, over any other.


Trade Errors


      As a fiduciary, Future Benefits, Inc. hasthe responsibility to effect orders correctly, promptly and in the bestinterests of our clients.  In the eventany error occurs in the handling of any client transactions, due to FutureBenefits, Inc.’s actions, or inaction, or actions of others, Future Benefits,Inc.’s policy is to seek to identify and correct any errors as promptly aspossible without disadvantaging the client or benefiting Future Benefits, any way.


      If the error is the responsibility ofFuture Benefits, Inc., any client transaction will be corrected and FutureBenefits, Inc. will be responsible for any client loss resulting from aninaccurate or erroneous order. The error is corrected by having Schwab removethe incorrect trade and replacing it with the correct trade. Schwab bears thecost of trade errors resulting in a loss of $100 or less. Future Benefits paysSchwab the entire amount of any trade errors resulting in a loss of more than$100. Schwab keeps all trade error gains.


      Future Benefits, Inc.’s policy andpractice is to monitor and reconcile all trading activity, identify and resolveany trade errors promptly, document each trade error with the appropriatesupervisory approval and maintain a trade error file.








      Thomas R. Hiten, the Chief ComplianceOfficer, has the responsibility for implementing and monitoring our tradingpolicies and practices, disclosures and recordkeeping for the firm.




      Future Benefits, Inc. has adopted variousprocedures to implement the firm’s policy and reviews to monitor and insure thefirm’s trading policies are observed, implemented properly and amended orupdated, which include the following:


·       Periodic supervisory reviews of the firm’strading practices.


·       Periodic reviews of the firm’s DisclosureDocument, advisory agreements, and other materials for the appropriatedisclosures of the firm’s trading practices and any conflicts of interests.









Personal Securities Transactions &Records





      Future Benefits, Inc.’s policy allowsemployees to maintain personal securities accounts provided any personalinvesting by an employee in any accounts in which the employee has a beneficialinterest, including any accounts for any immediate family or household members,is consistent with Future Benefits, Inc.’s fiduciary duty to its clients andconsistent with regulatory requirements.


      Each employee must identify any personalinvestment accounts and report all reportable transactions and investmentactivity on at least a quarterly basis to the firm’s Chief Compliance Officer.




      The Advisers Act requires advisers toidentify “advisory representatives,” the reporting of personal investments on aquarterly basis and the maintenance of records of personal securitiestransactions.  Advisers to registeredinvestment companies are required to adopt a Code of Ethics regarding personalinvestment activities under the Investment Company Act.


      In July 2004, the SEC adopted a new rule(Rule 204 A-1), similar to Rule 17j-1 under the Investment Company Act,requiring SEC advisers to adopt a code of ethics that would require, amongother things, setting ethical standards and compliance with the securitieslaws, safeguarding material non-public information about clients’ transactionsand portfolio holdings, initial and annual reports of securities holdings foraccess persons, and Form ADV Part II summary disclosure about the adviser’scode of ethics.


      The effective date of new rule 204 A-1 is8/31/2004, andthe compliance date is 1/7/2005.


      An investment adviser’s policies andprocedures represent an internal control and supervisory review to detect andprevent possible inside trading, conflicts of interests and possible regulatoryviolations.












      Thomas R. Hiten, the Chief ComplianceOfficer, has the responsibility for implementing and monitoring our policy onpersonal securities transactions and activities, practices, disclosures andrecordkeeping.




      Future Benefits, Inc. has adoptedprocedures to implement the firm’s policy on personal securities transactionsand reviews to monitor and insure the firm’s policy is observed, implementedproperly and amended or updated, as appropriate, which include the following:


·       Employees are to identify any personalinvestment account and any accounts in which the employee has a beneficialinterest, including any accounts for the immediate family and householdmembers, upon hire, annually thereafter and upon opening or closing anyaccount(s).

·       Employees must report all required informationfor covered personal securities transactions on a quarterly basis within 10days of the end of each calendar quarter to the Chief Compliance Officer.

·       All personal securities transactions are coveredexcept transactions in direct obligations of the Government of the UnitedStates, bankers acceptances, bank certificates of deposit, commercial paper andhigh quality short-term debt instruments, or shares issued by registeredaffiliated or unaffiliated open-end investment companies.

·       The Chief Compliance Officer will review allemployees’ reports of personal securities transactions for compliance with thefirm’s policies, including the Insider Trading Policy, regulatory requirementsand the firm’s fiduciary duty to its clients, among other things.







Insider Trading





      Future Benefits, Inc.’s policy prohibitsany employee from acting upon, misusing or disclosing any material non-publicinformation, known as inside information. Any instances or questions regarding possible inside information must beimmediately brought to the attention of the Chief Compliance Officer and anyviolations of the firm’s policy will result in disciplinary action and/ortermination.




      Various federal and state securities lawsand the Advisers Act (Section 204A) require every investment adviser toestablish, maintain and enforce written policies and procedures reasonablydesigned to prevent the misuse of material, non-public information in violationof the Advisers Act or other securities laws by the investment adviser or anyperson associated with the investment adviser.




      Thomas R. Hiten, the Chief ComplianceOfficer, has the responsibility for implementing and monitoring the firm’sInsider Trading Policy, practices, disclosures and recordkeeping.




      Future Benefits, Inc. has adopted variousprocedures to implement the firm’s policy and reviews to monitor and insurethat the firm’s policy is observed, implemented properly and amended orupdated, as appropriate, which include the following:


·       The Insider Trading Policy is distributed to allemployees, and new employees upon hire, and requires a written acknowledgementby each employee;

·       Advisory representatives must disclose personalsecurities accounts and report at least quarterly any reportable transactionsin their employee and employee-related personal accounts;

·       Employees must report to the Chief ComplianceOfficer all business, financial or personal relationships that may result inaccess to material, non-public information;

·       The Chief Compliance Officer reviews allpersonal investment activity for employee and employee-related accounts;







·       The Chief Compliance Officer provides guidanceto employees on any possible insider trading situation or question;

·       Future Benefits, Inc.’s Insider Trading Policyis reviewed and evaluated on a periodic basis and updated as may beappropriate; and

·       The Chief Compliance Officer prepares a writtenreport to management and/or legal counsel of any possible violation of thefirm’s Insider Trading Policy for implementing corrective and/or disciplinaryaction.













































I certify thatduring the year ended as of the date written below:


1.         I have fully disclosed all securitiesholdings in which I have, or a member of my immediate family has, a beneficialinterest.


2.          Ihave obtained pre-clearance for all securities transactions in which I have, oran immediate member of my family has, a beneficial interest except fortransactions exempt from pre-clearance or for which I have received anexception in writing from the CCO.


3.         Ihave reported all securities transactions in which I have, or any member of myimmediate family has, a beneficial interest except for transactions exempt frompre-clearance or for which I have received an exception in writing from theCCO.


4.         Ihave complied with the Code of Ethics in all other respects.













Print Name




Dated: _________________________________,201_









Copyright © Future Benefits, Inc. | 1781 Highland Avenue – Suite 205 Cheshire, Connecticut 06410 | Phone: (800) 272-4745 | Fax: (203) 272-2459
Securities offered through Triad Advisors, LLC
5185 Peachtree Parkway, Suite 280, Norcross, GA 30092. Member FINRA, SIPC

Advisory Services offered through Future Benefits, Inc. Future Benefits is not affiliated with Triad Advisors.