COLUMBIA MANAGEMENT GROUP FAMILY OF FUNDS
                     CODE OF ETHICS FOR PRINCIPAL EXECUTIVE
                          AND SENIOR FINANCIAL OFFICERS

I.   COVERED OFFICERS/PURPOSE OF THE CODE


          This Code of Ethics (the "Code") for the investment companies within
     the Columbia Management Group fund complex (collectively the "Funds" and
     each, a "Fund") applies to the Funds' Principal Executive Officer,
     Principal Financial Officer, Principal Accounting Officer, and Director of
     Trustee Administration (the "Covered Officers") for the purpose of
     promoting:


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

     o    full, fair, accurate, timely and understandable disclosure in reports
          and documents that a Fund files with, or submits to, the Securities
          and Exchange Commission ("SEC"), and in other public communications
          made by a Fund;

     o    compliance with applicable laws and governmental rules and
          regulations;

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

     o    accountability for adherence to the Code.


          Each Covered Officer shall adhere to a high standard of business
     ethics and shall be sensitive to situations that may give rise to actual or
     apparent conflicts of interest.


II.  ADMINISTRATION OF THE CODE


          The Boards of Trustees and Boards of Directors of the Funds
     (collectively, the "Board") shall designate an individual to be primarily
     responsible for the administration of the Code (the "Code Officer"). The
     Code shall be administered by the Columbia Management Group Compliance
     Department. In the absence of the Code Officer, his or her designee shall
     serve as the Code Officer, but only on a temporary basis.

          Each Fund has designated a chief legal officer (the "Chief Legal
     Officer") for purposes of the Sarbanes-Oxley Act of 2002 and the rules
     promulgated thereunder. The Chief Legal Officer of a Fund shall assist the
     Fund's Code Officer in administration of this Code. The Chief Legal Officer
     shall be responsible for applying this Code to specific situations in which
     questions are presented under it (in consultation with Fund counsel, where
     appropriate) and has the authority to interpret this Code in any particular
     situation. However, any



     waivers sought by a Covered Officer must be approved by each Audit
     Committee of the Funds (collectively, the "Audit Committee").

III. MANAGING CONFLICTS OF INTEREST


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

          Certain conflicts of interest arise out of the relationships between
     Covered Officers and a Fund and already are subject to conflict of interest
     provisions in the Investment Company Act of 1940 (the "Company Act") and
     the Investment Advisers Act of 1940 (the "Advisers Act"). For example,
     Covered Officers may not individually engage in certain transactions (such
     as the purchase or sale of securities or other property) with a Fund
     because of their status as "affiliated persons" of the Fund. A Fund's and
     its investment adviser's compliance programs and procedures are designed to
     prevent, or identify and correct, violations of those provisions. This Code
     does not, and is not intended to, repeat or replace those programs and
     procedures, and such conflicts fall outside of the parameters of this Code.

          Although typically not presenting an opportunity for improper personal
     benefit, conflicts may arise from, or as a result of, the contractual
     relationship between a Fund and its investment adviser, administrator,
     principal underwriter, pricing and bookkeeping agent and/or transfer agent
     (each, a "Service Provider") of which the Covered Officers are also
     officers or employees. As a result, this Code recognizes that the Covered
     Officers will, in the normal course of their duties (whether formally for a
     Fund or for a Service Provider, or for both), be involved in establishing
     policies and implementing decisions that will have different effects on the
     Service Provider and a Fund. The participation of the Covered Officers in
     such activities is inherent in the contractual relationship between the
     Fund and the Service Provider and is consistent with the performance by the
     Covered Officers of their duties as officers of a Fund. In addition, it is
     recognized by the Board that the Covered Officers may also be officers or
     employees of one or more other investment companies covered by this or
     other codes.

          Other conflicts of interest are covered by the Code, even if such
     conflicts of interest are not subject to provisions of the Company Act and
     the Advisers Act. The following list provides examples of conflicts of
     interest under the Code, but Covered Officers should keep in mind that
     these examples are not exhaustive. The overarching principle is that the
     personal interest of a Covered Officer should not be placed improperly
     before the interest of a Fund.



     Each Covered Officer must:


     o    not use personal influence or personal relationships improperly to
          influence investment decisions or financial reporting by a Fund
          whereby the Covered Officer or an immediate family member would
          benefit personally to the detriment of a Fund; and

     o    not cause a Fund to take action, or fail to take action, for the
          individual personal benefit of the Covered Officer or an immediate
          family member rather than the benefit of the Fund.1.

          There are some conflict of interest situations that must be approved
     by the Code Officer, after consultation with the Chief Legal Officer. Those
     situations include, but are not limited to,:


     o    service as director on the board of any public or private company;

     o    the receipt of any gifts in excess of $100 in the aggregate from a
          third party that does or seeks to do business with the Funds during
          any 12-month period;

     o    the receipt of any entertainment from any company with which a Fund
          has 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;

     o    any material ownership interest in, or any consulting or employment
          relationship with, any Fund service providers, other than its
          investment adviser, principal underwriter, administrator or any
          affiliated person thereof;

     o    a direct or indirect material financial interest in commissions,
          transaction charges or spreads paid by a Fund for effecting portfolio
          transactions or for selling or redeeming shares other than an interest
          arising from the Covered Officer's employment, such as compensation or
          equity ownership.

IV.  DISCLOSURE AND COMPLIANCE

     Each Covered Officer shall:

     o    be familiar with the disclosure requirements generally applicable to
          the Funds;

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1 For purposes of this Code, personal trading activity of the Covered Officers
shall be monitored in accordance with the Columbia Management Group Code of
Ethics. Each Covered Officer shall be considered an "Access Person" under such
Code. The term "immediate family" shall have the same meaning as provided in
such Code.



     o    not knowingly misrepresent, or cause others to misrepresent, facts
          about any Fund to others, whether within or outside the Fund,
          including to the Fund's trustees and auditors, and to governmental
          regulators and self-regulatory organizations;

     o    to the extent appropriate within his/her area of responsibility,
          consult with other officers and employees of the Funds and the adviser
          with the goal of promoting full, fair, accurate, timely and
          understandable disclosure in the reports and documents the Funds file
          with, or submit to, the SEC and in other public communications made by
          the Funds; and

     o    promote compliance with the standards and restrictions imposed by
          applicable laws, rules and regulations.

V.   REPORTING AND ACCOUNTABILITY

     Each Covered Officer must:

     o    upon adoption of the Code (or after becoming a Covered Officer),
          affirm in writing to the Board that he/she has received, read and
          understands the Code;

     o    annually affirm to the Board compliance with the requirements of the
          Code;

     o    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;

     o    notify the Chief Legal Officer and the Code Officer promptly if he/she
          knows of any violation of this Code; and

     o    respond to the trustee and officer questionnaires circulated
          periodically in connection with the preparation of disclosure
          documents for the Funds.


     The Code Officer shall maintain records of all activities related to this
Code.

     The Funds will follow the procedures set forth below in investigating and
enforcing this Code:

     o    The Chief Legal Officer and/or the Code Officer will take all
          appropriate action to investigate any potential violation reported to
          him/her;

     o    If, after such investigation, the Chief Legal Officer and the Code
          Officer believes that no violation has occurred, the Code Officer will
          notify the person(s) reporting the potential violation, and no further
          action is required;

     o    Any matter that the Chief Legal Officer and/or the Code Officer
          believes is a violation will be reported to the Audit Committee;



     o    If the Audit Committee concurs that a violation has occurred, it will
          inform and make a recommendation to the Board, which will consider
          appropriate action, which may include review of, and appropriate
          modifications to, applicable policies and procedures; notification to
          the Chief Executive Officer of Columbia Management Group; or a
          recommendation to sanction or dismiss the Covered Officer;

     o    The Audit Committee will be responsible for granting waivers in its
          sole discretion;

     o    Any changes to or waivers of this Code will, to the extent required,
          be disclosed as provided by SEC rules.

     The Chief Legal Officer shall:

     o    report to the Audit Committee quarterly any approvals provided in
          accordance with Section III of this Code; and

     o    report to the Audit Committee quarterly any violations of, or material
          issues arising under, this Code.

VI.  OTHER POLICIES AND PROCEDURES

          This Code shall be the sole code of ethics adopted by the Funds for
     the purposes of Section 406 of the Sarbanes-Oxley Act and the rules and
     forms applicable to registered investment companies thereunder. Insofar as
     other polices or procedures of the Funds or the Funds' Service Providers
     govern or purport to govern the behavior or activities (including, but not
     limited to, personal trading activities) of the Covered Officers who are
     subject to this Code, they are superseded by this Code to the extent that
     they overlap or conflict with the provisions of this Code. The Funds' and
     their investment advisers' and principal underwriter's codes of ethics
     under Rule 17j-1 under the Company Act and any policies and procedures of
     the Service Providers are separate requirements applicable to the Covered
     Officers and are not part of this Code.

VII. AMENDMENTS

          All material amendments to this Code must be approved or ratified by
     the Board, including a majority of independent directors.

VIII. 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 Board, the Covered
     Officers, the Chief Legal Officer, the Code Officer, outside audit firms
     and legal counsel to the Funds, and senior management of Columbia
     Management Group.



IX.  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 Fund, as to any fact,
     circumstance, or legal conclusion.