If a LACE employee is provided with confidential information, it must be marked and highlighted as confidential.  Only the initial analyst and the reviewing analyst will have access to this information, or discuss the data with the informing party.  If the confidential information is received over the telephone, the analyst must type it up and mark/highlight it as confidential.

Confidential information cannot be kept on a computer and must be kept locked in the analyst’s file cabinet.  If any LACE employee is found to abuse this procedure, they are subject to termination.

LACE discourages financial institutions from supplying confidential information and we rarely handle it.  We prefer that any information supplied to us be released as part of the rating process.

Code of Conduct

LACE Financial is committed to providing an independent and objective credit rating process that is based on honest and ethical conduct.  Our employees are subject to specific limitations that include:

1. Prohibited ownership in rated entities including securities or derivatives
2. Compliance with applicable government policies and regulations
3. Full disclosure of real or perceived conflicts of interest
4. Protection of confidential information
5. Avoidance of insider trading
6. Relationships or employment with rated entities must be fully disclosed
7. Employees are prohibited from soliciting money or gifts and are prohibited from accepting cash or gifts
8. Direct family members of the employee that work for a rated entity must be fully disclosed
9. Any relationships with the rated entity that may be perceived as creating a conflict must be disclosed and dealt with.

In addition, from a client service perspective, all requests from clients should be responded to or acknowledged within 24 hours (one business day).

LACE Financial Corporation
118 North Court Street
Frederick, MD 21701
Ph: 301.662.1011
Fax: 301.662.1458