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                                                       Exhibit 99.Code of Ethics

CODE OF ETHICS FOR PRINCIPAL EXECUTIVE OFFICER AND PRINCIPAL FINANCIAL OFFICER

I. COVERED OFFICERS/PURPOSE OF THE CODE

The Reserve Funds' has adopted this code of ethics (the "Code") for the
investment companies within the Reserve funds complex (collectively, the "Funds"
and each a "Fund"). The Code applies to the Principal Executive Officer and
Principal Financial Officer and Treasurer of the Funds (the "Covered Officers"
each set out in Exhibit A) for the purpose of promoting:

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

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

 iii. compliance with applicable laws and governmental rules and regulations;
the prompt internal reporting of violations of the Code to an appropriate person
or persons identified in the Code; and

 iv. accountability for adherence to the Code.

II. COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF
INTEREST

 Each Covered Officer should abide by a high standard of business ethics and
should be sensitive to situations that may give rise to actual as well as
perceived conflicts of interest. A "conflict of interest" occurs when a Covered
Officer's private interest interferes with the interest of, or his service to,
the Funds. A conflict of interest may arise if a Covered Officer, or a member of
his family, receives improper personal benefits as a result of his position with
the Funds.

 Certain conflicts of interest arise out of the relationship between Covered
Officers and the Funds and already are subject to conflict of interest
provisions in the Investment Company Act of 1940, as amended, ("ICA") and the
Investment Advisers Act of 1940, as amended, ("Advisers Act"). The Funds' and
the investment adviser's compliance programs and procedures are designed to
prevent or identify and correct violations of these 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 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, this Code 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 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 performance by the Covered Officers of their duties as
officers of the Funds. Thus, if performed in conformity with the provisions of
the ICA and the Advisers Act, such activities will be deemed to have been
handled ethically. In addition, it is recognized by the Board of Trustees of
each of the Funds ("Boards") 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 in the ICA and the Advisers Act. The
following provides examples of conflicts of interest, but is not an exhaustive
list.

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 A Covered Officer must not:

 i. use his personal influence or personal relationship improperly to influence
investment decisions or financial reporting by the Funds whereby the Covered
Officer would benefit personally to the detriment of the Funds; and

 ii. cause the Funds to take action or fail to take action for the individual
personal benefit of the Covered Officer rather than the benefit of the Fund.

 There are some conflicts of interest situations that may be discussed with the
General Counsel if material. Examples of these include:

 i. service as a director on the board of any public or private company;

 ii. receipt of any gift in excess of $100;

 iii. 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;

 iv. any ownership interest in or any consulting or employment relationship
with, any of the Funds' service providers, other than its investment adviser,
principal underwriter, administrator or any affiliated person;

 v. 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, such as compensation or equity ownership.

III. DISCLOSURE AND COMPLIANCE

 i. Each Covered Officer should be familiar with the disclosure requirements
generally applicable to the Funds;

 ii. Each Covered Officer should not knowingly misrepresent, or cause others to
misrepresent, facts about the Funds to others, whether within or outside the
Funds, including to the Funds' trustees and auditors, and to governmental
regulators and self-regulatory organizations;

 iii. Each Covered Officer should, to the extent appropriate within his or 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

 iv. It is the responsibility of each Covered Officer to promote compliance with
the standards and restrictions imposed by applicable laws, rules and
regulations.

IV. REPORTING AND ACCOUNTABILITY

 Each Covered Officer must:

 i. Upon adoption of this Code (or upon becoming a Covered Officer), affirm in
writing to the Board that he or she has received, read and understands this
Code;

 ii. Annually thereafter affirm to the Board that he or she has complied with
the requirements of the Code;

 iii. Not retaliate against any other Covered Officer or any employee of the
Funds or adviser for reports of potential violations that are made in good
faith; and

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 iv. Notify the General Counsel promptly of any violation of this Code. Failure
to do so is itself, a violation of this Code.

 The General Counsel is responsible for applying this Code to specific
situations in which questions are presented under it and has the authority to
interpret this Code in any particular situation. However, any approvals or
waivers sought by the Covered Officers will be considered by the Board.

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

 i. the General Counsel will take all appropriate action to investigate any
potential violations reported;

 ii. if, after such investigation, the General Counsel believes that no
violation has occurred, the General Counsel is not required to take any further
action;

 iii. any matter that the General Counsel believes is a violation shall be
reported to the Board;

 iv. if the Board concurs that a violation has occurred, it will consider
appropriate action, which may include review of and appropriate modifications to
applicable policies and procedures; notification to appropriate personnel of the
investment adviser or its board; or a recommendation to dismiss the Covered
Officer;

 v. the Board will be responsible for granting waivers, as appropriate; and

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

V. OTHER POLICIES AND PROCEDURES

 This Code shall be the sole code of ethics adopted by the Funds for purposes of
Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to
registered investment companies thereunder. Insofar as other policies or
procedures of the Funds, the Funds' adviser, principal underwriter or other
service provider govern or purport to govern the behavior or activities of the
Covered Officers who are subject to this Code, they are superceded by this Code
to the extent that they overlap or conflict with the provisions of this Code.
The Funds' and their investment adviser's codes of ethics under Rule 17j-1 of
the ICA are separate requirements applying to the Covered Officers and others
and are not part of this Code.

VI. AMENDMENTS

 Any amendments to this Code, other than amendments to Exhibit A, must be
approved or ratified by a majority vote of the Board.

VII. 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.

VII. INTERNAL USE

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

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                                    EXHIBIT A

Persons Covered by this Code of Ethics:

 Bruce R. Bent II (Co-Chief Executive Officer)

 Arthur T. Bent III (Co-Chief Executive Officer)

 Patrick J. Farrell (Chief Financial Officer)