Therefore, let it be known that a Code of Ethics is now set forth, enumerating the standards of professional behavior expected of all Certified Trust Compliance Professionals.

In conformance with this resolution, the NATACP Board of Directors further approves the principles set forth.

NATURE OF BUSINESS
Trust compliance independently assesses fiduciary activities and reporting for the purpose of identifying and managing actual or potential risks and exposures to the organization as a whole. To achieve those objectives the trust compliance professional must monitor compliance with policies, internal controls, laws and regulations that effectively safeguard the organization. To a large degree, the effectiveness of the trust compliance function is predicated upon maintaining current knowledge of compliance requirements of state and federal authorities.

OBJECTIVE
The Certified Trust Compliance Professional must have a single objective - to help protect the safety and soundness of the organization from risk associated with inadequate supervision of or non-compliance with applicable laws, regulations, or internal policies and controls.

The trust auditor must determine that there is conformance with the applicable federal and local laws, the terms of the governing instruments and sound fiduciary and investment principles. To this end, the trust auditor reviews policies, procedures and administrative controls through a qualitative analysis of the functions being. performed to ensure that mutual interests are protected. It is appropriate for trust auditors to function in the role of an in-house consultant to assist senior and unit management in developing a more efficient and effective organization. These functions should be discharged at a reasonable cost to the institution.

SCOPE
The activities of a trust compliance function include:

• Maintaining current knowledge of changes to applicable laws, regulations, and rulings by federal and state authorities to ensure that internal controls and checklists are current. Compliance professionals should create awareness of such changes through communication and education.
• Interpreting compliance requirements and assisting management in their implementation.
• Monitoring the effectiveness of fiduciary oversight responsibilities by the Board of Directors.
• Coordinating the development and implementation processes for applicable and comprehensive compliance policies and procedures. Compliance professionals should also oversee the structure that controls total fiduciary policy development and communication to all personnel.
• Reviewing the system of internal controls for ensuring compliance with applicable laws, regulations and internal policies to determine that the institution is clearly in compliance.
• Testing and sampling fiduciary accounts and assets to ensure conformity to compliance internal controls.
• Analyzing and reviewing appropriate regulatory reports to ensure that all information reflected on the reports is accurate and fully represents all reporting categories and instructions.
• Serving as liaison between management and all regulatory examiners and Internal/external auditors during examinations and audits to ensure a dedicated resource for providing information and follow-up to all issues.

RESPONSIBILITY AND AUTHORITY
The trust compliance function is controlled by the policies established by the board of directors and, from time-to-time, by appropriate rulings by regulatory authorities. The purpose, authority and responsibility of the trust compliance professional individually, or of the institution's compliance function, should be defined in a formal written document that is accepted by the board of directors. This document should make clear those areas assigned to the compliance function and/or to the trust compliance professional, specify the unrestricted scope of the work to be performed and direct that the compliance professionals are not to participate in or have any responsibility for the activities or reports they analyze.

INDEPENDENCE AND OBJECTIVITY
The institution's compliance function, including the trust compliance professionals, must be independent of all functions that are being analyzed. Independence has been defined as the ability to act with integrity and objectivity. Independence permits the compliance professional to perform an objective evaluation and provide suggestions for improvement. Independence permits compliance professionals to render the impartial and unbiased judgments essential to the discharge of their responsibilities as a compliance professional. Independence is achieved through organizational status and objectivity.

Organizational status must be such that the compliance professional has unqualified access to management and can ensure that adequate consideration is given to improper, illegal or imprudent activities.

Objectivity dictates that compliance professionals maintain independence combined with a positive attitude in meeting compliance challenges in a dramatically changing environment. They must make a constant assessment and reassessment of techniques and areas of risk for compliance emphasis and develop and retain a holistic view relative to carrying out their responsibilities in an unbiased and professional manner.