SBREfunds Code of Ethics for Members & Users - SBREfunds CODE OF ETHICS


To create the world’s most extensive and trusted network of small balance real estate entrepreneurs and high net worth accredited investors interested in passive real estate investing.


To connect, educate, and empower the two groups, engender mutual understanding of each other’s needs, concerns and objectives, and create mutual benefit for all.


In order to be listed in the Marketplace, the company/individual must:

  • Be a member in good standing.
  • Have passed a background check acceptable to (and pass updated background checks on an annual basis).
  • Each principal of the company (or individual member) must complete a Principal Questionnaire acceptable to (and complete an updated PQ as requested by
  • Agree to abide by the SBRE Entrepreneur Code of Ethics (as described below) at all times and in all dealings, including with accredited investor members.


Given its mission, expects its CapitalFlow members to adopt and adhere to a code of ethics to guide its actions, behaviors and intentions, including when working with accredited investor members,, Fairway America and its business in general. The Code contains broad principles reflecting the types of behaviors that and Fairway America expect towards constituents of all types.

This policy is not intended as a stand-alone policy. It does not embody the totality of and Fairway America’s ethical standards or core operating principles, nor does it attempt to answer every ethical questions or issue that may arise. Rather, it is one element of a broader effort we continually make to create and maintain a quality organization and community that gives ethical conduct the absolute highest priority. This Code will be reviewed and updated periodically. By agreeing to follow the Code, each CapitalFlow member agrees to abide by the following principles:

  • I will endeavor at all times to be honest, forthright and transparent in my dealings with investors,, Fairway America, and each other.
  • I will disclose what I am required to disclose legally as well as what I may not be legally required to disclose, but would need to know in order to make good decisions if I were in the investor’s shoes.
  • I will consider and try to treat every deal as if it were 100% of my own money being invested.
  • I will do what is morally right and ethical when needed to protect shareholder’s interests, even if painful in the short run, rather than what is merely expedient.
  • I will adhere to my underwriting guidelines when making investments. I will be respectful of investor’s time and their wishes in terms of communication method, frequency and style.
  • I will respond to inquiries, business interactions, and dealings with others in the community in a timely and professional manner.
  • I will comply with all applicable federal, state and local laws, regulations and fiduciary responsibilities (including securities laws) to the best of my ability and knowledge.
  • I will be accountable at all times to abide by this Code. I will honor my commitments and promises.
  • I will strive for continual improvement and professional growth in my SBRE business and endeavor to produce the best work of which I am capable.

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