RFBS℠ Code of Conduct

Preamble

This Code of Conduct works alongside the RFBS℠ Code of Ethics. Where the Code of Ethics sets out the core principles a Designee (a “Designee”) commits to, this Code of Conduct sets out specific, observable standards for applying those principles in practice. Federal Employee Benefits Advocates, LLC (“FEBA”) administers both documents on behalf of the RFBS℠ program, and a violation of this Code of Conduct is treated as a violation of the Code of Ethics for purposes of the disciplinary process described there.

A. Duties Owed to Clients

A.1 Best-Interest Standard

A Designee shall act in the best interest of the client at all times when providing guidance on federal benefits, retirement timing, or related financial decisions. This duty applies whether the Designee is compensated by fee, commission, or a combination of both.

A.2 Honest and Clear Communication

A Designee shall communicate with clients honestly, in plain language, and without exaggeration. A Designee shall not omit information a reasonable federal employee would consider necessary to make an informed decision about FERS, TSP, FEGLI, FEHB, Social Security, or a recommended alternative.

A.3 Scope of Engagement

Before beginning substantive work, a Designee shall reasonably identify the scope of the engagement with the client — for example, whether the engagement is a one-time federal retirement review, an ongoing advisory relationship, insurance placement, investment management, or a combination — and shall clarify scope in writing when practicable.

A.4 Suitability and Individual Circumstances

A Designee shall base recommendations involving TSP rollovers, FEGLI conversion or replacement, FEHB elections, survivor benefit elections, or retirement timing on a reasonable assessment of the client’s individual circumstances, including age, health, family situation, other assets, risk tolerance, and stated goals — not on a one-size-fits-all script.

A.5 Disclosure of Compensation and Conflicts

A Designee shall disclose, before or at the time of recommendation, how the Designee is compensated for the recommendation (fee, commission, or both), and any other conflict of interest that could reasonably be expected to affect the recommendation, including affiliations, incentive trips, production bonuses, or ownership interests in a recommended product or company.

A.6 No Misrepresentation of Products or Costs

A Designee shall not misrepresent the features, costs, surrender terms, guarantees, or risks of any product recommended as an alternative to, or in coordination with, a federal benefit. A Designee shall identify at least one reasonable alternative the client may wish to consider when recommending replacement of an existing federal benefit.

A.7 Confidentiality

A Designee shall keep client information confidential and shall use it only to provide services to that client, except as required by law, necessary to prevent client harm, or specifically authorized in writing by the client.

A.8 Respectful, Non-Discriminatory Conduct

A Designee shall treat clients, prospective clients, colleagues, and the public with respect and courtesy, and shall not engage in harassment or unlawful discrimination on the basis of a protected characteristic.

A.9 No High-Pressure or Fear-Based Tactics

A Designee shall not use high-pressure sales tactics, artificial urgency, or exaggerated claims of risk to federal benefits (such as implying FERS, TSP, or FEHB are at imminent risk of elimination) in order to prompt a client decision.

A.10 Referral When Outside Competence

A Designee who is asked to address a matter outside the Designee’s licensure, training, or competence — including legal, tax, or specialized investment matters — shall say so plainly and refer the client to a qualified professional rather than offer guidance beyond the Designee’s expertise.

A.11 Written Summary of Recommendations

For engagements involving a recommendation to roll over TSP assets, replace FEGLI, alter FEHB coverage, or elect a survivor benefit, a Designee shall provide the client a written summary of the recommendation and its principal costs, benefits, and risks.

A.12 Safeguarding Documents and Assets

A Designee shall not take custody of client funds or securities except in compliance with all applicable law and required registrations, shall safeguard any original client documents in the Designee’s possession, and shall return them promptly upon request.

B. Duties When Providing Federal Benefits Guidance

B.1 Currency of Federal Benefits Knowledge

A Designee shall maintain a working, current understanding of FERS, TSP, FEGLI, FEHB, Social Security, and applicable special provisions (LEO, FF, ATC, CBPO), and shall complete continuing education under the schedule established by FEBA.

B.2 Accurate Representation of the Designation

A Designee shall accurately describe what the RFBS℠ designation is — evidence of federal-benefits training, examination, and an ethical commitment — and shall not state or imply that the designation authorizes the practice of law, investment advice, or the sale of securities or insurance without separate licensure.

B.3 No Implied Government Affiliation

A Designee shall not represent, imply, or allow a client to believe that the Designee is affiliated with, endorsed by, or acting on behalf of OPM, the TSP, the Social Security Administration, or any other federal agency.

B.4 Coordination Across Benefits

When a recommendation touches more than one federal benefit — for example, a FEGLI decision that interacts with survivor benefits, or an FEHB decision that interacts with Medicare enrollment timing — a Designee shall reasonably consider how the benefits interact rather than evaluating each in isolation.

B.5 Truthful Marketing

Marketing and advertising by a Designee referencing the RFBS℠ designation shall be truthful, balanced, and substantiated, shall comply with applicable SEC, FINRA, and state insurance advertising rules, and shall use the service-mark notation (℠). A Designee may reference the designation only while in good standing.

C. Duties to the Program and the Public

C.1 Cooperation with FEBA

A Designee shall respond promptly and honestly to reasonable requests for information from FEBA regarding the Designee’s compliance with this Code of Conduct and the Code of Ethics, including in connection with a complaint investigation.

C.2 Self-Reporting

A Designee shall notify FEBA within thirty (30) days of any final regulatory or self-regulatory disciplinary action, any criminal charge or conviction involving fraud, dishonesty, or breach of trust, any civil judgment or arbitration award arising from the Designee’s professional conduct, or personal bankruptcy filed within the prior ten years.

C.3 Directory Accuracy

A Designee shall keep the Designee’s public directory profile — including contact information, licenses held, and states served — current and accurate, and shall promptly notify FEBA of any material change.

C.4 Supporting the Verification System

A Designee shall not discourage a client or prospective client from independently verifying the Designee’s standing through the public RFBS℠ verification lookup or from filing a good-faith complaint if one is warranted.

C.5 Fair Dealing with Other Designees

A Designee shall not make false or misleading statements about another Designee, another financial professional, or a competing program in order to gain a business advantage.

Relationship to the Code of Ethics

This Code of Conduct implements the principles set out in the RFBS℠ Code of Ethics. A violation of any standard in this Code of Conduct is evaluated, investigated, and, if warranted, sanctioned under the complaints and disciplinary process described in that document. Anyone may file a complaint regarding a Designee’s conduct.

Amendments

FEBA may amend this Code of Conduct from time to time. Material amendments will be communicated to Designees in advance of their effective date. Continued use of the RFBS℠ designation after the effective date of an amendment constitutes acceptance of the amended Code.

Contact

Federal Employee Benefits Advocates, LLC
Attn: RFBS℠ Program
3295 Co Rd 47
Florence, AL 35630
contact@registeredfederalbenefitsspecialist.com