MONEY MANAGEMENT ASSOCIATES, L.P.
RUSHMORE INVESTMENT BROKERS, INC.
And
THE RUSHMORE FUNDS

CODE OF ETHICS

     WHEREAS, Money Management Associates, L.P. (the "Adviser") is a registered investment adviser under the Investment Advisers Act of 1940 and provides investment advisory services to investment companies; and

     WHEREAS, the investment advisory business involves decisions and information that may have at least a temporary impact on the market price of securities, thus creating a potential for conflicts of interest between investment advisers and their clients; and

     WHEREAS, the Adviser has a fiduciary duty with respect to each portfolio under management and to the shareholders of the Adviser's investment company clients who must take precedence over the interests of the Adviser, its officers and employees, thus requiring adherence to the highest standards of conduct by the officers and employees of the Adviser; and

     WHEREAS, Rushmore Investment Brokers, Inc. (a "Distributor") is a registered broker-dealer under the Securities Exchange Act of 1934 and intends to serve as distributor of shares of investment companies;

     WHEREAS, practical steps must be taken to ensure that no action is taken by an officer or employee of the Adviser/Distributor which is, or appears to be, adverse to the interests of the Adviser/Distributor or any of their client accounts, including the definition of standards of conduct for such employees, while at the same time avoiding unnecessary restrictions on the actions of such officers and employees; and

     WHEREAS, American Gas Index Fund, Inc., Fund for Government Investors, Fund for Tax-Free Investors, Inc. and The Rushmore Fund, Inc. (the "Funds" or "The Rushmore Funds") are open-end management investment companies registered under the Investment Company Act of 1940 (the "1940 Act"); and

     WHEREAS, the Funds are advised by the Adviser; and

     WHEREAS, the Distributor intends to distribute shares of investment companies; and

     WHEREAS, the Board of Directors/Trustees ("Directors") of the Funds have received a certification from the Adviser that the procedures contained in the following Code of Ethics (the "Code") and the rules and procedures adopted thereunder (the "Procedures") are reasonably necessary to prevent access persons from violating the Code and Procedures; it is

     RESOLVED, that the Partners of the Adviser, the Board of Directors of the Distributor and the Directors of the Funds hereby adopt the following Code pursuant to the provisions of Rule 17j-1 under the 1940 Act, as amended.

     The Code applies to "employees." Unless otherwise indicated, the term "employee" means: (1) all officers, directors and employees, including "investment persons," "portfolio managers" and "access persons," as defined in the rules and procedures ("Procedures") adopted hereunder, of the Adviser/Distributor and their affiliates and wholly owned and indirect subsidiaries and (2) officers, directors (who maintain offices at the Adviser/Distributor) and employees of the Adviser/Distributor who have an active part in the management, portfolio selection, underwriting or shareholder functions with respect to the Adviser's or Distributor's investment company clients. (Hereinafter, references to the Adviser includes the Distributor and each of their affiliates).

• The term "employee" does not include directors or trustees of any investment company managed by the Adviser, provided that they do not regularly obtain current information concerning the investment recommendations or decisions made by the Adviser on behalf of client accounts ("independent directors"). These directors may obtain periodic updates of investment decisions after the funds have effected these transactions.

      The General Partner of the Adviser shall appoint a Compliance Officer (the "Compliance Officer") among whose duties will be administration of the Code of Ethics. The Compliance Officer (or his/her designee) shall have the responsibility for interpreting the provisions of the Code, for adopting and implementing Procedures for the enforcement of the provisions of the Code, for identifying and informing all "access persons" of their reporting obligations, and for determining whether a violation of the provisions of the Code, or of any such related Procedures has occurred.

     The Compliance Officer (or designee) will monitor personal investment activity by all "access persons" (as defined in the Procedures attached as the Appendix), both before and after any trade occurs and will review all securities transaction and holding reports, conduct education seminars as appropriate, obtain annual employee certifications as deemed appropriate, and maintain all appropriate records in the manner and to the extent required under the federal securities laws. In the event of a finding that a violation has occurred, the Compliance Officer (or designee) shall take such action as he/she deems appropriate, which may include recommendations to the General Partner of the Adviser or to the board of any of its affiliates or subsidiaries, on the imposition of sanctions or initiation of disgorgement proceedings. The Compliance Officer (or designee) shall also make recommendations and submit reports to the Boards of Directors/Trustees of the Adviser's investment company clients regarding any such violations and the actions taken with respect thereto.

     The Procedures Are Part of the Code

     From time to time, the Compliance Officer shall, with the consent of the Funds' Directors, adopt Procedures to carry out the intent of the Code. Among other things, the Procedures require certain new employees to complete an Asset Disclosure Form and such other forms as deemed appropriate by the Compliance Officer. Such Procedures are hereby incorporated into the Code and are made a part of the Code. Therefore, a violation of the Procedures shall be deemed a violation of the Code.

_______________________

These rules and procedures (collectively, "Procedures") have been adopted by Money Management Associates, L.P. (the "Adviser"), Rushmore Investment Brokers, Inc. (a "Distributor") and American Gas Index Fund, Inc., Fund for Government Investors, Fund for Tax-Free Investors, Inc. and The Rushmore Fund, Inc. (the "Funds" or "The Rushmore Funds") to carry out the intent of the Code of Ethics of the Adviser, Distributor and the Funds (the "Code") and are incorporated by reference into and made a part of the Code. The Code has been approved by the Adviser, the Distributor and by the Board of Directors/Trustees of the Funds ("Fund Directors").

The Compliance Officer (or designee) has the responsibility for interpreting the provisions of the Code, for adopting and implementing these Procedures, and for determining whether a violation of the provisions of the Code or of these Procedures has occurred and, if so, for imposing appropriate sanctions. Further, the Code authorizes the Compliance Officer (or designee) to adopt procedures, rules and guidelines designed to establish, maintain and enforce written policies and procedures reasonably designed to prevent the misuse of material non-public information. 

Do the Code and Procedures Apply To You?

All employees, directors/trustees, officers or general partners of the Funds, Adviser, Distributor and their affiliates should review the Code and Procedures. Hereinafter, references to the Adviser include the Distributor and their affiliates. Any questions regarding the Code or the Procedures should be referred to the Compliance Officer (or designee) of the Adviser.

Definitions

For purposes of these Procedures, the following terms shall have the meanings set forth below:

"Beneficial Ownership" means:

• having or sharing, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, a direct or indirect pecuniary interest in any class of equity securities.
• The term "pecuniary interest" means the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the subject securities.

Generally, a person will be regarded as having a direct or indirect beneficial ownership interest in securities held in his/her name, as well as in the name of a spouse, minor children who live with such person, and any other relative (parents, adult children, brothers, sisters, in-laws, etc.) who shares the same household with such person. See Exhibit A to these Procedures for a more complete description of beneficial ownership, as well as examples of beneficial ownership.

"Employee" has the same meaning as set forth in Section 2 of the Code. In addition, the following definitions apply:

 "Reportable Security" means any security that must be reported to the Compliance Officer (or designee) after execution of a trade (see Exhibit B for examples).

"Security Requiring Prior Approval" means any reportable security that must be pre-cleared by the Compliance Officer (or designee) prior to execution of a trade (see Exhibit B for examples).

General Prohibitions for All Employees

The Adviser and the Funds have determined that the following courses of conduct are prohibited for all the Adviser's employees:

Insider Trading

Every employee is forbidden from trading, either personally or on behalf of others (including client accounts managed by the Adviser), on material non-public information or communicating material non-public information to others in violation of the law. This conduct is frequently referred to as "insider trading." This policy applies to all employees of the Adviser and extends to activities within and outside their duties at the Adviser. See the Friedman, Billings & Ramsey Group, Inc. Insider Trading Compliance Procedures for a description of "insider trading" and special procedures that are designed to detect and prevent "insider trading."

From time to time, employees may obtain material, non-public information or establish special or "insider" relationships with one or more issuers of securities (i.e., the employee may become an officer or director of an issuer, a member of a creditor committee that engages in material negotiations with an issuer, etc.). In these cases, the Compliance Officer (or designee) may maintain a "Restricted List" containing the names of issuers whose securities are not eligible for purchase or sale by employees and/or client accounts.

Employees who are deemed to be access persons may not trade, either personally or on behalf of client accounts of the Adviser, in a security of an issuer appearing on the Restricted List. With respect to personal transactions of employees, the Compliance Officer (or designee) will advise each employee during the prior approval process if a security appears on the Restricted List. With respect to trading on behalf of client accounts, the Compliance Officer (or designee) will advise the portfolio managers thereof in writing when any issuers are added to or deleted from the Restricted List.

Except as noted below, an employee shall not solicit or accept from a broker/dealer or other vendor that transacts business with the Adviser or its client accounts any gifts or gratuities or other things of value. For this purpose, gifts and gratuities and other things of value do not include unsolicited entertainment (including meals or tickets to cultural or sporting events) that are not so frequent or extensive as to raise any question of impropriety. An employee may not accept unsolicited gifts or other things of more than de minimis value from any person or entity that does business with or on behalf of an investment company client account. In any such case, the value may not exceed $100 per giver per year.

Employees shall not undertake a business activity or practice for compensation that is in competition with the Adviser unless they have received the written consent of the Compliance Officer (or designee) of the Adviser. For this purpose, "business activity or practice" includes any service that the Adviser currently makes available for compensation. In addition, employees who are deemed to be investment persons are prohibited from serving on the board of directors/trustees of certain organizations without prior written approval from the Compliance Officer (or designee) (see Section 5(B)(6) of the Code). In the relatively small number of instances in which board service is authorized, investment persons serving as directors normally should be isolated from those making investment decisions through "Chinese Wall" or other procedures.

Employees shall also avoid any action, whether for personal profit or otherwise, that results in an actual or potential conflict of interest with the Adviser or its client accounts, or which may be otherwise detrimental to the interest of the Adviser or its client accounts. Such conflict may also arise from the purchase and sale for a client account of securities in which an officer, director or employee of the Adviser has an economic interest. Moreover, such conflict may arise in connection with vendor relationships in which such employee has any direct or indirect financial interest, family interests or other personal interest. Such conflicts must be resolved in favor of the Adviser's client, or if a vendor, in favor of the Adviser.

Upon commencement of duty with the Adviser, each investment and access person shall disclose, on the appropriate form (see Exhibit C), all holdings of securities to the Compliance Officer (or designee). An employee who is deemed to be an investment person shall not cause or attempt to cause client accounts to acquire or dispose of any such security (including any option, warrant or other right or interest relating to such security) unless the employee shall first disclose to the Compliance Officer (or designee) all facts reasonably necessary to assure that any conflicts of interest relating to such security are resolved in a manner that is not disadvantageous to client accounts.

The disclosures as described above are intended to bring to the attention of the Compliance Officer (or designee) any actual or apparent conflicts of interest and to prevent employees from exerting, or appearing to exert, improper influence on the management of client accounts.

The failure of an employee who is deemed to be a portfolio manager to recommend an investment opportunity to, or to purchase an investment opportunity for, a client account in order to obtain a personal benefit will be considered a course of conduct that deprives a client account of an investment opportunity. Therefore, such conduct will be considered to be a violation of Section 5(B)(5) of the Code. An example of this type of prohibited conduct is to effect a personal transaction in a security and to intentionally fail to recommend, or to fail to effect, a suitable client account transaction in such security in order to avoid the appearance of a conflict of interest.

Employees shall not acquire or dispose of beneficial ownership of a security if such acquisition or disposition is based upon the employee's knowledge of actions already taken, being taken or being considered by the Adviser on behalf of any of its client accounts. Such prohibited conduct will be considered to violate one or more of Sections 5(B)(3), 5(B)(4) and 5(B)(9) of the Code. Examples of this type of prohibited conduct include:

• for personal gain, an employee uses knowledge of a future purchase of a security by a client account and buys the security or acquires direct or indirect beneficial ownership of the security before the client account buys the security; or
• for personal gain, an employee uses knowledge of a future sale of a security by a client account and sells the security for any account with respect to which the employee is the direct or indirect beneficial owner before the client account sells the security (e.g., the employee sells short a security based on knowledge of a future sale of the security by a client account).

Employees, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired² by the Funds may not:

_____________________

___  Please check the box if you wish to disclaim beneficial ownership of any security listed on this report.

To: Compliance Officer (or designee)

From:

Date:

Subject: Personal Securities Transaction Report*

This Personal Securities Transaction Report ("Report") is submitted pursuant to the Procedures under the Code of Ethics of Money Management Associates, L.P., Rushmore Investment Brokers, Inc. and The Rushmore Funds. The table below lists information with respect to purchases or sales in any reportable security in which I may be deemed to have a direct or indirect beneficial ownership interest. I understand that I may have direct or indirect beneficial ownership of securities of which certain other persons are the record owners as well as securities of which I am the record owner, and I have included transactions in such securities in this Report where applicable. I also understand that I am not required to include in this Report transactions effected for any account over which I do not have any direct or indirect beneficial interest, influence or control.

I hereby certify that:

* Important Note: This Report is due no later than 10 calendar days after the end of the calendar quarter in which the transaction took place.

** Purchase, sale or any other type of disposition or acquisition.

*** Interest rate and maturity date (if applicable).

**** Check this column, if you wish to disclaim beneficial ownership of any security listed on this Report.

     I have read the Code of Ethics of Money Management Associates, L.P., Rushmore Investment Brokers, Inc. and The Rushmore Funds, the related Procedures and the Friedman, Billings & Ramsey Group, Inc. Insider Trading Compliance Procedures, and I understand the requirements thereof. I certify that I will comply with the above. I understand that any violation of the above may lead to sanctions or other significant remedial action.

     I have read the Code of Ethics of Money Management Associates, L.P., Rushmore Investment Brokers, Inc. and The Rushmore Funds, the related Procedures and the Friedman, Billings & Ramsey Group, Inc. Insider Trading Compliance Procedures, and I understand the requirements thereof. I certify that I will comply with the above. I understand that any violation of the above may lead to sanctions or other significant remedial action. I understand that I may also be subject to disgorgement proceedings for any short-term transactions that I may conduct that are inconsistent with Sections 5(B)(15)-(16) of the Code.

     As appropriate, I have disclosed to the Compliance Officer (or designee) all personal securities holdings for which I have direct or indirect beneficial ownership and I will continue to do so on an annual and quarterly (if appropriate) basis as long as I am employed with any of the entities names above or any of their affiliates, and I will continue to keep this information current with the Compliance Officer (or designee).

     I understand that there may be prohibitions, restrictions and blackout periods on certain types of securities transactions and that I am prohibited from acquiring any securities in an initial public offering (IPO).

     I have read the Code of Ethics of Money Management Associates, L.P., Rushmore Investment Brokers, Inc. and The Rushmore Funds, the related Procedures and the Friedman, Billings & Ramsey Group, Inc. Insider Trading Compliance Procedures. I understand the requirements thereof, and except as otherwise disclosed to the Compliance Officer (or designee), I certify that I have, to date, complied with and will continue to comply with such requirements, including, but not limited to, those requirements relating to gifts. I understand that any violation of the above may lead to sanctions or significant remedial action.

     I have read the Code of Ethics of Money Management Associates, L.P., Rushmore Investment Brokers, Inc. and The Rushmore Funds, the related Procedures (collectively, the "Code") and the Friedman, Billings & Ramsey Group, Inc. Insider Trading Compliance Procedures. I understand the requirements thereof, and except as otherwise disclosed to the Compliance Officer (or designee), I certify that I have, to date, complied with, and will continue to comply with, such requirements. I understand that any violation of the above may lead to sanctions or significant remedial action. I understand that I may also be subject to disgorgement proceedings for any short-term transactions that I may conduct that are inconsistent with Sections 5(B)(15) - (16) of the Code.

     As appropriate, I have reported or disclosed all personal securities transactions required to be reported or disclosed pursuant to the requirements of the Code. I have reported to the Compliance Officer (or designee) all additions and/or deletions of accounts for reportable securities for which I have direct or indirect beneficial ownership held at broker/dealers, companies or other institutions. I have disclosed all personal securities for which I have direct or indirect beneficial ownership. I will continue to do so on an annual and quarterly (if appropriate) basis as long as I am employed by the entities named above or their affiliates.

     I understand that there may be prohibitions, restrictions and blackout periods on certain types of securities transactions and that I am prohibited from acquiring any securities in an initial public offering (IPO).

Employees who are deemed to be access persons desiring to purchase or sell a security requiring prior approval must request approval from the Compliance Officer (or designee) prior to execution of such transaction. (Note: Pre-clearance is also required for transactions in securities requiring prior approval whenever an employee has or acquires a beneficial ownership interest in such security.) Failure to obtain pre-clearance when required will generally be considered a violation of these Procedures.

Employees are encouraged to seek pre-clearance for all of their transactions in reportable securities; however, pre-clearance is required only for transactions in securities requiring prior approval. Exhibit B summarizes the difference between reportable securities and securities requiting prior approval.

The procedure described below shall be followed in order to ascertain whether a proposed personal securities transaction by an employee should be approved or disapproved. Employees should recognize that this procedure is designed to provide legal protection to the Adviser, its clients and employees.

Completion of Part I of Pre-Clearance Form

Completion of Part II of Pre-Clearance Form

Considerations During the Pre-Clearance Process

For access persons, if any client account is considering the purchase of the same or equivalent security, the Compliance Officer (or designee) will disapprove the proposed transaction if it is a purchase of the same or equivalent security of the same issuer. If any client account is considering the sale of the same or equivalent security, the Compliance Officer (or designee) will disapprove the transaction if it is a sale of the same or equivalent security of the same issuer.

For access persons, if a client account has recently purchased a security, ordinarily there is no reason for the Compliance Officer (or designee) to disapprove a subsequent purchase of the same or equivalent security of the same issuer, provided all client account transactions have taken precedence over the employee's proposed transaction and there are no anticipated client account transactions in the same or equivalent security of the same issuer. Likewise, if a client account has recently sold a security, ordinarily there is no reason for the Compliance Officer (or designee) to disapprove a subsequent sale of the same or equivalent security, so long as there are no anticipated client account transactions in the same or equivalent security of the same issuer. Investment persons are subject to the seven-day blackout period on all proposed transactions as described in Section 2(C)(4) below.

If any client account has, within the past seven calendar days, sold the same or equivalent security of the same issuer, the Compliance Officer (or designee) disapproves the access person's proposed security transaction if it is a purchase. If any client account has, within the past seven calendar days, purchased the same or equivalent security of the same issuer, the Compliance Officer (or designee) will disapprove the access person's transaction if it is a sale. Investment persons are subject to the seven-day blackout period on all proposed transactions as described in Section 2(C)(4) below.

Depending on the circumstances in each case, the Compliance Officer (or designee) may impose a "cooling-off period" longer or shorter than the seven-day period described above. Some of these circumstances could include whether the security is thinly traded, the number and dollar volume of transactions of employees and client accounts, and the employee's involvement in the investment process. (Note: The day of the last client account trade is counted as the first day of this five day period.)

A.     Same Day.

Access persons are prohibited from executing a securities transaction on any day during which a client account has a pending, "buy" or "sell" order in that same or equivalent security until that order is executed or withdrawn.

Exceptions. Notwithstanding anything to the contrary, an access person may engage in transactions in the same securities or similar securities as the Funds provided that (1) the transactions are aggregated and (2) in the opinion of the trader and the Compliance Officer (or designee), the transaction is not likely to adversely affect the price at which a Fund's order will be executed. Generally, transactions in securities with an average monthly trading volume of $100 million or more shall be presumed to meet these criteria. In addition, an access person may engage in transactions in mutual fund shares and government securities without regard to the blackout period.

B.     Seven-Days

Investment persons are prohibited from buying or selling a security within at least seven calendar days before or after a client account trades in the same or equivalent security. (Note: The day of the last client account trade is counted as the first day of this seven calendar day period.)

If any client account purchases or sells a security within seven days before or after a trade by an investment person, the Compliance Officer (or designee) has the authority to require that the employee's trade be unwound or canceled. The Compliance Officer (or designee) shall require that the employee take such action as necessary to unwind, reverse or disgorge such securities. The Compliance Officer (or designee) shall direct the employee to relinquish any profits obtained as a result of unwinding or canceling the trade. Any losses or associated commissions realized on trades within the prescribed period are the responsibility of the employee who executed the trade during a blackout period and as a result had to unwind or cancel the trade.

C.     30-Days

Investment persons are prohibited from profiting in the purchase and voluntary sale, or sale and voluntary purchase, of the same or equivalent security within 30 calendar days of a trade by any client account. If such employee purchases and sells the same or equivalent security or other property of the same issuer during this 30-day blackout period, the Compliance Officer (or designee) shall direct the employee to relinquish any profits obtained from such short-term transactions. The Compliance Officer (or designee) may adopt rules providing for exceptions upon application on a case-by case basis.

D.     Conflict of Interest Monitoring

All personal trades executed by access persons will be monitored by the Compliance Officer (or designee) for current and future conflicts of interest with client accounts.

Any transaction in an option by an access person will be disapproved by the Compliance Officer (or designee) if a client account holds, at the time of the employee's proposed transaction, a long or short position in either the option itself or in the underlying security to which the option relates. If the option and the security to which the option relates are not held by client accounts at the time of the employee's proposed transaction, the employee's transaction in the option may be approved, but only if there are no apparent conflicts of interest as a result of the pre-clearance process.

As described previously, an option relating to common stock will be treated as an "equity security" for purposes of the pre-clearance process. If the employee has sought pre-clearance for an options transaction, the Compliance Officer (or designee) reminds the employee that pre-clearance is required for both the opening and closing transaction. He/she also advises the employee that if the opening transaction is approved, the closing transaction could be difficult to approve due to apparent conflicts of interest or competing obligations that arise after the time the employee's opening transaction was approved. In cases where the pre-clearance process indicates that bona fide, apparent conflicts of interest exist or where obligations to client accounts appear to be in competition with the securities transactions of employees, the first preference and priority must be given to transactions of client accounts. Consequently, the approval of options transactions can be delayed in order to establish that first preference and priority has been given to client accounts. Effectively, therefore, options transactions take on an added element of risk -- the rapidly declining time value of options is coupled with the need, in some cases, to delay closing transactions of individuals to ensure that first preference and priority is given to the execution of any pending client account transactions.

Because of the foregoing, employees must recognize that closing options transactions can be disapproved or delayed in certain cases and that additional risks can therefore result from engaging in options transactions.

Investment persons may not acquire direct or indirect beneficial ownership or otherwise purchase securities issued during an IPO.

Investment persons are prohibited from acquiring an unregistered security issued in a private (or limited) placement without the prior written approval of the Compliance Officer (or designee). Under normal circumstances, such approval will not be withheld if the employee demonstrates in writing that: (1) the investment is not suitable for one or more of the Adviser's clients, (2) the investment opportunity was unique to the individual circumstances of the employee, (3) the investment did not involve employment with the Adviser or its affiliated broker-dealer as a consideration by the offeree, and (4) no overreaching would or could occur. Investment persons who have been authorized to acquire securities in a private placement must disclose such investment to the Investment Policy Committee when such investment person plays a part in any subsequent consideration of any investment in the issuer by a client account and that the client's decision to purchase securities of the issuer should be subject to an independent review by the Committee.

If an access person wishes to purchase a corporate bond that is held in one or more client accounts and which is currently not rated or rated less than investment grade, the Compliance Officer (or designee) disapproves the proposed transaction. (For further details, see Section 4(K) of the Procedures adopted under the Code.)

Approval

Unless the employee's proposed transaction has been disapproved, the Compliance Officer (or designee) will indicate his/her approval of the transaction by signing the Pre-Clearance Form. The form is kept on file in the Compliance Office, as required under Section 6(B) of the Procedures.

Ordinarily, the securities transactions of employees will be disapproved if they fail to meet the foregoing approval criteria. However, in some circumstances it may be appropriate for a securities transaction to be approved even though one or more of the above criterion indicates that the transaction should be disapproved. In such cases, the reason for justifying such a trade will be described in the "Comments" section of the Pre-Clearance Form or on a supplemental sheet to the form.

Execution of an approved securities transaction is permissible through the date indicated in Part I of the Pre-Clearance Form, provided that, ordinarily, execution shall be effected no later than the day following the date of the request for pre-clearance.

If any employee believes that a disapproved securities transaction should have been approved, he/she may appeal the decision of the Compliance Officer (or designee) by presenting a written request for approval to the President of the Adviser.

(Note: Execution of all approved transactions should be effected no later than the date following the date the request for prior approval was approved.)

PART 1: To be completed by Money Management Associates, L.P. employee seeking pre-clearance.