Montoya Wealth Management's
Code of Ethics

Montoya Wealth Management Group LLC (the "firm") and its associates have a duty of utmost good faith to act solely in the interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard of conduct and integrity. Our fiduciary duty compels all associates to act with the utmost integrity in all of our dealings. 

Our firm adheres to its Code of Ethics and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. 

This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients. 

Standards of Conduct 

·        The interests of clients will be placed ahead of the firm's or any associate's. 

·        All known or potential conflicts of interest will be disclosed to our clients. 

·        Associates are expected to conduct their personal securities transactions in accordance with the policy and will strive to avoid any actual conflict of interest with the client. Questions regarding the appearance of a conflict with a client should be discussed with the Chief Compliance Officer before taking action that may result in an actual conflict.

·        Associates will not take inappropriate advantage of their position with the firm. 

·        Associates are expected to always comply with securities laws, which include anti-fraud provisions. 

·        Investment advisor representatives will be appropriately registered or exempted in each jurisdiction they conduct advisory business as required by regulation. 

·        Business titles will be accurate and avoid public misperception as to the associates position, education, and background. 
 

Protection of Non-Public Information

Associates will exercise diligence and due care in maintaining and protecting client non- public personal information and will be familiar with the firm's published privacy policies. Any known or suspected privacy breach must be immediately reported.

The firm may have written arrangements with third-party providers to perform certain client or firm services. While associates may be directly involved in this activity, they are expected to refrain from divulging information regarding securities recommendations or client securities holdings to any individual outside of the firm except: 

·        To complete transactions or account changes (i.e., communications with custodians). 

·        As necessary to maintain or service a client account (i.e., communications with a client attorney). 

·        With a service provider that supports the firm and only following the firm entering into a contractual agreement that prohibits the disclosure of confidential information and only as necessary to carry out its assigned responsibilities. 

·        As permitted or required by law. 
 

Personal Conduct

Associates are to conduct themselves with the utmost integrity and avoid any actual or perceived conflict of interest with our clients. In this spirit, the following are required: 

·        Insider Trading —Associates must review and acknowledge their understanding and adherence to the firm's Insider Trading Policy.

·        Acceptance of Gifts — All associates are prohibited from receiving any gift, gratuity, hospitality or other offering of more than de minimis value from any person or entity doing business with the firm. This gift policy generally excludes items or events where the employee has reason to believe there is a legitimate business purpose and must be pre-approved by the Chief Compliance Officer. 

·        Political Contributions — The firm does not engage in direct or indirect political contributions. Any political contributions for or by the firm or anyone associated with the firm in a solicitation capacity is strictly prohibited. The firm's policy is not designed to disallow personnel from engaging in their right of free election participation but does place certain contribution level restrictions pursuant to investment advisor regulation. The firm will be guided by rule of the Investment Advisers Act with regard to political contribution limits. Therefore, the firm permits associates to make aggregate contributions of up to $350 per election to an elected official or candidate for which the associate is entitled to vote, and up to $150 per election to an elected Official or candidate for which the associate is not entitled to vote. These de minimis exceptions are available only for contributions by individual associates, not the firm. Under both exceptions, primary and general elections would be considered separate elections. Associates are obligated to promptly inform the firm of any political contribution as they occur. 

·        Splitting Of Fees — Sharing or splitting of advisory fees will only occur with other appropriately registered personnel and only as approved by the firm. 

·        Director for an Outside Company — The firm prohibits an associate from serving as a director for an outside entity product, service or activity that may be a conflict of interest. 

·        Outside Business Interests - Any associate wishing to engage in business activities outside of the firm must seek approval from the Principal prior to the engagement. 

·        Payment of Services —Advisory client payment of services will be made to the firm only. 
 

Employee Acknowledgement

New associates will acknowledge they have read, understand, and agree to comply with our Code of Ethics within the 10 days of hiring with the firm. All associates will annually reaffirm their understanding of the firm's Code of Ethics.  

Personal Securities Trading Policy

Personal securities of associated and related persons of the firm will be reported, and the firm will periodically review, personal securities accounts and holdings. The firm defines an associated person to mean any associate of the investment advisor; a related person includes immediate family members who receive any economic benefit from an associated person (i.e., spouse, minor, etc.).

NOTE: A lack of a transaction report submission will be interpreted as a lack of any transaction during the reporting period. Should it later be determined that a transaction in fact occurred, the associated person will be referred to the CCO. 

Code of Ethics and Personal Securities Trading Policy Violations

All associates are required to promptly report any violation of this policy to the Principal, including the discovery of a possible violation committed by another employee. Items that should be reported include, but are not limited to, non-compliance with federal laws, conduct that is harmful to our clients or the firm, etc. 

As noted above, employees are encouraged to report any violations or apparent violations and such reports will not be negatively viewed, even if the reportable event, upon further review, is determined to not be a violation and the employee reported such apparent violation in good faith. 

Code of Ethics and Personal Securities Policy Sanctions

Upon discovering a violation of policy, the firm may impose any sanctions as deemed appropriate, including disgorgement of profits, trade reversals, and up to and including termination.