Code of Ethics

Hunter Financial Advisors, Inc. has adopted the following Code of Ethics, which applies  
to all Employees and Advisory Representatives to promote honest and ethical conduct
and compliance with applicable laws, rules, and regulations, particularly as related to the 
public disclosure.

Unless otherwise indicated, the term “Employee” as used herein means:  all officers,
directors and office employees of Hunter Financial Advisors, Inc.  The term “Advisory
Representative” as used herein means:  all Investment Advisor Representatives registered
with Hunter Financial Advisors, Inc.

1. Engage in and promote honest and ethical conduct, including the ethical handling
of actual or apparent conflicts of interest between personal and professional
relationships.

2. Act in good faith, responsibly, with due care, competence, prudence and diligence, without misrepresenting material facts or allowing one’s independent judgment or decisions to be subordinated to one’s personal interest;

3. Produce full, fair, accurate, timely, and understandable disclosure in reports and documents the Company files with, or submits to, the Securities and Exchange Commission and other regulators and in other public communications made by  the company.

4. Take all reasonable measures to protect the confidentiality of non-public information about the Company and its customers and vendors obtained or created in connection with your activities and to prevent the unauthorized disclosures of such information.

5. Comply with applicable government laws, rules , and regulations; and

6. Promptly report (see below) any information you may have concerning (a) significant or material deficiencies or weaknesses in the design or operation of the internal controls of the Company, (b) any fraud, whether or not material,  involving any member of management or other employee who has a significant  role in the financial reporting, disclosures or internal controls of the Company, or (c) any other matters that could have a material adverse effect on Hunter Financial Advisors’ ability to record, process, summarize and report financial data. 

Each Employee and Advisor Representative is accountable for his or her adherence to
this Code of Ethics and the policies of the Company.  Any violation of this Code of 
Ethics may result in disciplinary action up to and including termination.

As Employees and Advisor Representatives, you are obligated to report any possible violation of this Code of Ethics to any of the following:

     The Chief Compliance Officer, of Hunter Financial Advisors; or
     the Chief Compliance Officer, of First Allied Securities Inc.; or
     the Investment Advisory Unit, Office of the Attorney General, State of New York.

All Employees and Advisory Representatives will be required to sign either electronically or via written statement an Acknowledgment Statement indicating that you have received a copy of the Code of Ethics.  The Code of Ethics is available upon written request to Hunter Financial Advisors, Inc.


REVISED ON JANUARY 10, 2007