Draft — pending legal review. This document is a good-faith draft prepared for review by counsel. It is not yet a final policy of the RFBS℠ program and should not be relied upon as such.
Last revised: May 31, 2026
Standards
RFBS℠ Code of Ethics & Professional Conduct
Every Registered Federal Benefits Specialist℠ agrees in writing to abide by this Code of Ethics as a condition of earning and maintaining the designation. The Code exists to protect federal employees and their families, to support designees in delivering principled service, and to preserve the integrity of the designation.
Preamble
Federal employees, retirees, and their families rely on competent, honest, and diligent guidance to navigate retirement, benefits, and related financial decisions. The RFBS℠ designation signals that a professional has both the specialized knowledge to assist this population and the commitment to the principles below. Federal Employee Benefits Advocates, LLC (“FEBA”) administers this Code on behalf of the RFBS℠ program.
1. Core Principles
Each RFBS℠ designee (a “Designee”) shall observe these core principles in all professional dealings:
1.1 Client First
A Designee shall act in the best interests of the client, place client interests ahead of the Designee’s own, and provide advice with reasonable care, skill, and prudence.
1.2 Integrity
A Designee shall be honest and candid in all communications and shall not knowingly make any material misrepresentation, omission, or misleading statement to a client, prospective client, regulator, FEBA, or the public.
1.3 Competence
A Designee shall provide services only in areas where the Designee has the necessary knowledge, skill, training, licensure, and experience, and shall refer clients to qualified professionals when a matter exceeds the Designee’s competence.
1.4 Diligence
A Designee shall perform engagements promptly, carefully, and thoroughly, including reasonable investigation of facts relevant to recommendations.
1.5 Disclosure of Material Conflicts
A Designee shall identify and disclose, in writing and in plain language, all material conflicts of interest, including compensation arrangements, affiliations, and incentives that could reasonably be expected to influence the Designee’s recommendations.
1.6 Confidentiality
A Designee shall protect non-public client information and shall not disclose, sell, or use it for any purpose other than the delivery of services to that client, except as required by law or as specifically authorized by the client.
1.7 Compliance with Law
A Designee shall comply with all applicable federal, state, and local laws, rules, and regulations, including those of the SEC, FINRA, state securities and insurance regulators, and any self-regulatory organization with jurisdiction over the Designee’s practice.
1.8 Professional Conduct
A Designee shall act with professionalism, treat clients, colleagues, and the public with respect, refrain from harassing or discriminatory conduct, and avoid conduct that reflects adversely on the Designee or on the RFBS℠ designation.
1.9 Continuing Competence
A Designee shall maintain currency in federal benefits, retirement rules, and related developments, including by completing required continuing education.
1.10 Independence of the Designation
A Designee shall accurately represent what the RFBS℠ designation is and is not. A Designee shall not state or imply that the RFBS℠ designation, by itself, authorizes the practice of law, the provision of investment advice, the sale of securities or insurance, or any other regulated activity for which separate licensure is required.
2. Specific Standards
2.1 Marketing and Advertising
- Marketing materials shall be truthful, balanced, and substantiated and shall comply with the SEC Marketing Rule, FINRA communications rules, state insurance advertising rules, and any other applicable standard.
- The RFBS℠ designation may be referenced only by Designees in good standing. The service-mark notation (℠) shall be used.
- A Designee shall not claim or imply government endorsement, guaranteed results, or any benefit not actually provided.
- Testimonials and endorsements, if used, shall comply with all applicable SEC and FINRA rules, including required disclosures about compensation, material conflicts, and material conditions.
2.2 Recommendations Involving Federal Benefits
- Recommendations to roll over Thrift Savings Plan (TSP) assets, to replace Federal Employees’ Group Life Insurance (FEGLI), to alter Federal Employees Health Benefits (FEHB) coverage, or to elect survivor benefits shall be made only after a documented assessment of the client’s individual circumstances.
- A Designee shall disclose any commissions, fees, surrender charges, or other costs associated with a recommended product or strategy, and shall identify reasonable alternatives the client may wish to consider.
- A Designee shall not misrepresent the features, costs, or risks of federal benefits programs or of any private product offered as a substitute.
2.3 Custody, Funds, and Documents
A Designee shall not take custody of client funds or securities except in compliance with all applicable laws and any required registrations. A Designee shall safeguard original client documents and shall return them promptly upon request.
2.4 Documentation
A Designee shall maintain reasonable records of recommendations, material communications, disclosures, and engagement terms for a period consistent with applicable regulatory and program requirements.
3. Program Requirements for Designees
To earn and maintain the RFBS℠ designation, a Designee shall:
- complete the FedEd Academy™ curriculum;
- pass the RFBS℠ proctored examination;
- execute the RFBS℠ Designee Agreement and this Code of Ethics;
- pay the annual maintenance fee and complete required continuing education on the schedule established by FEBA;
- maintain the licenses, registrations, and credentials required for the services the Designee provides;
- disclose to FEBA within thirty (30) days any of the following events: (i) a final regulatory or self-regulatory disciplinary action; (ii) a criminal charge or conviction involving fraud, dishonesty, breach of trust, money laundering, or financial misconduct; (iii) a civil judgment or arbitration award arising from professional conduct; (iv) personal bankruptcy filed within the prior ten (10) years; or (v) any matter that would reasonably be material to the Designee’s standing under this Code.
4. Complaints and Disciplinary Process
4.1 How to File a Complaint
Anyone — including federal employees, retirees, family members, other Designees, employers, regulators, or members of the public — may file a complaint regarding a Designee or the RFBS℠ program. Complaints may be submitted through our complaint intake form or by email to complaints@registeredfederalbenefitsspecialist.com. Anonymous complaints are accepted but may be more difficult to investigate.
4.2 Acknowledgment and Initial Review
FEBA will acknowledge each complaint within five (5) business days and will conduct an initial review to determine whether the complaint, if substantiated, would constitute a violation of this Code. Matters outside the scope of this Code (for example, an ordinary fee dispute) will be referred or closed with notice to the complainant.
4.3 Investigation
For matters within scope, FEBA will request a written response from the Designee and may request additional information, documents, or interviews from the Designee and the complainant. The Designee is required to cooperate. FEBA will treat complaint records as confidential, subject to legal and regulatory obligations.
4.4 Determination and Sanctions
After investigation, FEBA will determine whether a violation of this Code has occurred. Available sanctions include, in increasing order of severity:
- private written caution;
- private written reprimand;
- required remedial education or supervision;
- public censure noted in the Designee’s directory listing for a stated period;
- suspension of the RFBS℠ designation for a stated period; and
- permanent revocation of the RFBS℠ designation.
Sanctions will be proportionate to the nature, severity, and recurrence of the conduct, and will consider any aggravating or mitigating circumstances. FEBA may impose interim measures — including suspension of directory listing — pending the outcome of an investigation where appropriate to protect the public.
4.5 Reporting to Authorities
FEBA will refer conduct that appears to violate federal or state law, securities regulations, or insurance regulations to the relevant authority, and will cooperate with regulatory and law enforcement inquiries.
4.6 Appeal
A Designee subject to a sanction of public censure or higher may appeal in writing within thirty (30) days. The appeal will be reviewed by an individual not involved in the original determination, whose decision will be final under this Code. The right to appeal does not extend the time for any legal or regulatory deadline.
5. Voluntary Resignation
A Designee may voluntarily relinquish the RFBS℠ designation at any time by written notice to FEBA. Voluntary resignation while a complaint is open does not terminate the investigation, and the outcome will be recorded.
6. Amendments
FEBA may amend this Code 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.
7. Contact
Federal Employee Benefits Advocates, LLC
Attn: RFBS℠ Program
3295 Co Rd 47
Florence, AL 35630
contact@registeredfederalbenefitsspecialist.com
