Exhibit (a) (1)	Code of Ethics

Adoption of a Code of Ethics for Senior Officers

WHEREAS, the Fund's management recommends to the Board the adoption of a
Senior Officer Code of Ethics in compliance with the Sarbanes-Oxley Act;

ACCORDINGLY BE IT FURTHER RESOLVED, that the following
resolution is hereby adopted and approved:

BE IT RESOLVED, that the SM&R Family of Funds adopts the Senior Officers
Code of Ethics as follows:

THE SM&R FAMILY OF FUNDS
CODES OF ETHICS FOR SENIOR OFFICERS

STATEMENT OF GENERAL PRINCIPLES

The Board of Directors of the SM&R Family of Funds (the "Funds") have adopted
this Code of Ethics ("Code") applicable to their Principal Executive Officer and
Principal Financial and Accounting Officer and others who may serve in similar
functions (the "Covered Officers") to promote:

* Honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional relationships;

* Full, fair, accurate, timely and understandable disclosure in documents
filed with the Securities and Exchange Commissions ("SEC") and in other public
communications;

* Compliance with applicable governmental laws, rules and regulations;

* The prompt internal reporting to an appropriate person or persons identified
in the Code of violations of the Code; and

* Accountability for adherence to the Code.

No Code can address every situation that a Senior Officer might face.   As a
guiding principle, Senior Officers should adhere to a high standard of business
ethics and strive to implement the spirit as well as the letter of applicable
laws, rules and regulations, and to provide the type of clear and complete
disclosure and information that Fund shareholders have a right to expect.

SECTION 1. HONEST AND ETHICAL CONDUCT

Each Covered Officer named in Exhibit A of this Code owes a duty to the Funds
and the Funds shareholders to act with integrity and honesty in the conduct of
his/her duties and responsibilities while maintaining the confidentiality of
information.   Integrity requires, among other things, being honest and candid.
Deceit and subordination of principle are inconsistent with integrity.

SECTION 2.  AVOIDANCE OF CONFLICTS OF INTEREST

	Definition:
A "conflict of interest" occurs when a Covered Officer's private interest
interferes with the interests of, or his service to, the Funds.  For example,
a conflict of interest would arise if a Covered Officer, or a member of his
family, receives improper personal benefits as a result of his position with
the Funds.

Covered Officers must avoid any actual or apparent conflict of interest, direct
or indirect, between personal and professional relationships.  A Covered
Officer should not engage in personal, business or professional relationships
or dealings which would impair his/her independence or judgement or adversely
affect the performance of his/her duties in the best interests of the Funds and
its shareholders.  Any relationship or dealing that would present a conflict for
a Covered Officer could also present a conflict if it is related to a member of
his/her immediate family.

Certain conflicts of interest covered by this Code arise out of the
relationships between Covered Officers and the Funds and are already subject
to conflict of interest provisions in the Investment Company Act of 1940 and
the Investment Advisers Act of 1940.  This Code does not, and is not intended
to, repeat or replace these programs and procedures, and such conflicts fall
outside of the parameters of this Code.

It is recognized by the Board that, conflicts may arise from, or as a result
of, the contractual relationship between the Funds and the investment adviser
of which the Covered Officers are also officers or employees.  As a result, the
Board recognizes that the Covered Officers will, in the normal course of their
duties (whether formally for the Funds or for the adviser, or for both), be
involved in establishing policies and implementing decisions that will have
different effects on the adviser and the Funds.  The Board recognizes that
participation of the Covered Officers in such activities is inherent in the
contractual relationship between the Funds and the adviser and is consistent
with the expectation of the Board of the performance by the Covered Officers
of their duties as officers of the Funds.

Each Covered Officer must:

* Handle any actual or apparent conflict of interest ethically;
* Avoid conflicts of interest wherever possible;
* Not use his/her personal influence or personal relationships to influence
investment decisions or financial reporting by the Funds whereby the Covered
Officer would benefit personally to the detriment of any of the Funds;
* Not cause any of the Funds to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the benefit of
any of the Funds;

Not use knowledge of portfolio transactions made or contemplated for the Funds
to profit or cause others to profit, by market effect of such transactions;

Some conflict of interest or potential conflict of interest situations should
always be discussed with the Funds Legal Counsel, if material, include:

* Service as a director on the board of any public or private company;
* Any outside business activity that detracts from an individual's ability to
devote appropriate time and attention to his/her responsibilities with the
Funds;
* The receipt of any entertainment from any company with which the Funds
have current or prospective business dealings unless such entertainment is
business-related, reasonable in cost, appropriate as to time and place, and not
so frequent as to raise any question of impropriety or other formulation as the
Funds already use in another code of ethics or conduct;
* A direct ownership interest in, or any consulting or employment relationship
with, any of the Funds; service providers, other than its investment adviser,
principal underwriter, or other SM&R and its parent organization's affiliated
entities and other than a de minimis ownership interest (for purposes of this
section of the Code an ownership interest of 1% or less shall constitute a de
minimis ownership interest, and any ownership interest of more than 1% creates
a rebuttable presumption that there may be a material conflict of interest); and
* A direct or indirect financial interest in commissions, transaction charges
or spreads paid by the Funds for effecting portfolio transactions or for
selling or redeeming shares other than an interest arising from the Covered
Officer's employment with SM&R, its subsidiaries, its parent organizations and
any affiliates or subsidiaries thereof, such as compensation or equity
ownership, and other than an interest arising from a de minimis ownership
interest in a company with the Funds execute portfolio transactions or a company
that receives commissions or other fees related to its sales and redemptions of
shares of the Funds (for purposes of this section of the Code an ownership
interest of 1% or less shall constitute a de minimis ownership interest, and an
ownership interest of more than 1% creates a rebuttable presumption that there
may be a material conflict of interest).

SECTION 3.  DISCLOSURE

Covered Officers have a supervisory role with respect to the financial
information included in reports filed with regulatory agencies and public
disclosures by the Funds, and have particular responsibilities in connection
with these communications.

Therefore, Each Covered Officer must:

* familiarize himself/herself with the disclosure requirements applicable to
the Funds as well as the business and financial operations of the Funds;
* not knowingly misrepresent, or cause others to misrepresent, facts about the
Funds to others, whether within or outside the Funds, including to the Funds
directors and auditors, and to governmental regulators and self-regulatory
organizations;
* ensure that reasonable steps are taken within his/her area of responsibility
and consult with other officers and employees of the Funds and the adviser to
promote full, fair, accurate, timely and understandable disclosure in all
regulatory filings, as well as when communicating with the Funds' shareholders
or the general public, in accordance with applicable law.

SECTION 4. COMPLIANCE

It is each Funds policy to comply in all material respects with all applicable
governmental laws, rules and regulations.   It is the personal responsibility
of each Covered Officer to adhere to the standards and restrictions imposed by
those laws, rules and regulations, including those relating to affiliated
transactions, accounting and auditing matters.

SECTION 5.  REPORTING AND ACCOUNTABILITY

Each Covered Officer must:

* Upon receipt of the Code or upon becoming a Covered Officer, sign and submit
to the Chief Compliance Officer of the Funds an acknowledgement stating that
he/she has received, read and understands the Code;
* Annually thereafter submit a form to the Chief Compliance Officer of the
Funds confirming that he/she has received, read and understands the Code and
has complied with the requirements of the Code;
* Notify Legal Counsel promptly if he/she becomes aware of any existing or
potential violation of this Code;.
* Not retaliate against any other Covered Officer or any employee of the Funds
or their affiliated persons for reports of potential violations that are made
in good faith.

Except as described otherwise below, Legal Counsel is responsible for applying
this Code to specific situations in which questions are presented to him/her
and has the authority to interpret this Code in any particular situation.
Legal Counsel shall take all action he/she considers appropriate to investigate
any actual or potential violations reported to him/her.  Legal Counsel is
authorized to consult, as appropriate, with Chairman of the Audit Committee of
the Board and is encouraged to do so.

Legal Counsel is responsible for granting waivers and determining sanctions, as
appropriate.  Additionally, the Chairman of the Audit Committee may also
consider approvals, interpretations, or waivers sought by the Covered Officers.


The Funds will follow these procedures in investigating and enforcing this
Code;

* Legal Counsel will take all appropriate action to investigate any potential
violations reported to him/her;
* violations and potential violations will be reported to the Chairman of the
Audit Committee of the Board after the investigation has been completed;
* if the Chairman of the Audit Committee determines that a violation has
occurred, he/she will inform the Board, which will take all appropriate
disciplinary or preventive action;
* appropriate disciplinary action, may include a letter of censure, suspension,
dismissal or, in the event of criminal or other serious violations of law,
notification to the SEC or other appropriate law enforcement authorities;
* Legal Counsel will be responsible for granting waivers, as appropriate; and
* any changes to or waivers of this Code will, to the extent required, be
disclosed on Form N-CSR as provided by SEC rules.

SECTION 6.  OTHER POLICIES AND PROCEDURES

The Funds' and their investment adviser's and principal underwriter's codes of
ethics under Rule 17j-1 of the Investment Company Act and the Corporate
Policies and Conflict of Interest and Sensitive Transaction Policies of SM&R's
parent, American National Insurance Company are separate requirements applying
to the Covered Officers and others, and are not part of this Code.

SECTION 7.  AMENDMENTS

Any amendments to this Code, other than amendments to Exhibit A, must be in
written form and approved or ratified by a majority vote of the Funds Boards,
including a majority of the independent directors.


SECTION 8.  CONFIDENTIALITY

All reports and records prepared or maintained pursuant to this Code will be
considered confidential and shall be maintained and protected accordingly.
Except as otherwise required by law or this Code, such matters shall not be
disclosed to anyone other than the appropriate Board and its counsel.

SECTION 9.  INTERNAL USE

The Code is intended solely for the internal use by the Funds and does not
constitute an admission, by or on behalf of any Funds, as to any fact,
circumstance, or legal conclusion.



Date:     October 1, 2003

Exhibit A

Persons Covered by this Code of Ethics

Michael W. McCroskey, President, Chief Executive Officer

Brenda T. Koelemay, Chief Financial Officer

THE SM&R FAMILY OF FUNDS
CODES OF ETHICS FOR SENIOR OFFICERS

ACKNOWLEDGEMENT

I hereby acknowledged that I am a Principal Officer of the Funds and I am aware
of and subject to the Funds' Code of Ethics.  Accordingly, I have read and
understood the requirements of the Code of Ethics and I am committed to fully
comply with the Code of Ethics.

I recognize my obligations to promote:

1. Honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional relationships;

2. Full, fair, accurate, timely, and understandable disclosure in reports and
documents that the Funds file with, or submit to, the Commission and in other
public communications made by the Funds; and

3. Compliance with applicable governmental laws, rules and regulations.

Date:  November 3, 2006			Name:/S/ Michael W. McCroskey

					Title: President, Chief Executive Officer


THE SM&R FAMILY OF FUNDS
CODES OF ETHICS FOR SENIOR OFFICERS

ACKNOWLEDGEMENT

I hereby acknowledged that I am a Principal Officer of the Funds and I am aware
of and subject to the Funds' Code of Ethics.  Accordingly, I have read and
understood the requirements of the Code of Ethics and I am committed to fully
comply with the Code of Ethics.

I recognize my obligations to promote:

1.  Honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional relationships;

2. Full, fair, accurate, timely, and understandable disclosure in reports and
documents that the Funds file with, or submit to, the Commission and in other
public communications made by the Funds; and

3. Compliance with applicable governmental laws, rules and regulations.

Date:  November 3, 2006			Name:__/S/ Brenda T. Koelemay__

					Title:_Vice President, Chief Financial Officer