AMERICAN EXPRESS CERTIFICATE CO
S-1/A, EX-99, 2000-07-28
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EXHIBIT INDEX

Exhibit 16(a)10(o):           Selling Dealer Agreement

Exhibit 16(a)10(p)(1):        Code of Ethics for Registrant

Exhibit 16(a)10(p)(2):        Code of Ethics for Registrant's investment advisor
                              and principal underwriters


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