EXHIBIT 14.1

                             FAIR ISAAC CORPORATION

                 CODE OF ETHICS FOR SENIOR FINANCIAL MANAGEMENT

         Fair Isaac Corporation (the "Company") has adopted this Code of Ethics
for Senior Financial Management to promote honest and ethical conduct and to
deter wrongdoing. This Code applies to the Company's Chief Executive Officer,
Chief Financial Officer, Controller and other employees performing similar
functions who have been identified by the Chief Executive Officer (the "Senior
Financial Management"). The obligations of this Code supplement, but do not
replace, the Company's Code of Business Conduct and Ethics and any other code of
conduct or ethics policy applicable to employees of the Company generally.

         Any person who has information concerning any violation of this Code by
any member of the Senior Financial Management shall promptly bring such
information to the attention of the General Counsel or Chief Executive Officer
of the Company. If the General Counsel or Chief Executive Officer determines
that a conflict of interest exists, he or she will refer the matter to the Audit
Committee of the Board of Directors for resolution. Violations of this Code may
subject the employee to appropriate actions, such as censure, suspension or
termination. Such actions shall be reasonably designed to deter wrongdoing and
to promote accountability for adherence to this Code. The Audit Committee of the
Board of Directors shall consider any request for a waiver of this Code and any
amendments to this Code and all such waivers or amendments shall be disclosed
promptly as required by law or Securities and Exchange Commission ("SEC")
regulation.

         All members of the Senior Financial Management shall:

         1.       Act honestly and ethically in the performance of their duties
                  at the Company.

         2.       Avoid actual or apparent conflicts of interest between
                  personal and professional relationships.

         3.       Provide full, fair, accurate, timely and understandable
                  disclosure in reports and documents that the Company files
                  with, or submits to, the SEC and in other public
                  communications by the Company.

         4.       Comply with rules and regulations of federal, state and local
                  governments and other private and public regulatory agencies
                  that affect the conduct of the Company's business and the
                  Company's financial reporting.

         5.       Act in good faith, responsibly, with due care, competence and
                  diligence, without misrepresenting material facts or allowing
                  the member's independent judgment to be subordinated.

         6.       Respect the confidentiality of information acquired in the
                  course of work, except when authorized or legally obligated to
                  disclose such information.



         7.       Share knowledge and maintain skills relevant to carrying out
                  the member's duties within the Company.

         8.       Proactively promote ethical behavior as a responsible partner
                  among peers and colleagues in the work environment and
                  community.

         9.       Achieve responsible use of and control over all assets and
                  resources of the Company entrusted to the member.

         10.      Promptly bring to the attention of the General Counsel or
                  Chief Executive Officer any information concerning (a)
                  significant deficiencies in the design or operation of
                  internal controls which could adversely affect the Company's
                  ability to record, process, summarize and report financial
                  data or (b) any fraud, whether or not material, that involves
                  management or other employees who have a significant role in
                  the Company's financial reporting, disclosures or internal
                  controls.

Acknowledged:

____________________________________
[Employee]