T. ROWE PRICE GROUP, INC.
                      STATEMENT OF POLICY
                               ON
                    SECURITIES TRANSACTIONS


BACKGROUND INFORMATION.

    Legal  Requirement.   In  accordance  with  the  requirements   of
    the  Securities  Exchange  Act  of 1934,  the  Investment  Company
    Act  of  1940,  the Investment Advisers Act of 1940,  the  Insider
    Trading  and  Securities Fraud Enforcement Act of  1988,  and  the
    various  United  Kingdom  laws and regulations,  Price  Group  and
    the  mutual  funds  ("Price Funds") which  its  affiliates  manage
    have    adopted   this   Statement   of   Policy   on   Securities
    Transactions ("Statement").

    Price  Advisers'  Fiduciary  Position.   As  investment  advisers,
    the  Price  Advisers  are in a fiduciary position  which  requires
    them  to  act  with an eye only to the benefit of  their  clients,
    avoiding  those  situations  which  might  place,  or  appear   to
    place,  the  interests of the Price Advisers  or  their  officers,
    directors  and  employees  in  conflict  with  the  interests   of
    clients.

    Purpose  of  Statement.   The  Statement  was  developed  to  help
    guide  Price  Group's  employees  and  independent  directors  and
    the  independent  directors  of the Price  Funds  in  the  conduct
    of their personal investments and to:

          eliminate  the possibility of a transaction occurring  that
       the Securities and Exchange Commission or other regulatory bodies
       would  view  as illegal, such as Front Running (see  definition
       below);

          avoid situations where it might appear that Price Group  or
       the Price Funds or any of their officers, directors, employees,
       or other personnel had personally benefited at the expense of a
       client or fund shareholder or taken inappropriate advantage  of
       their fiduciary positions; and

          prevent,  as  well  as  detect,  the  misuse  of  material,
       non-public information.

    Those   subject   to   the   Code,   including   the   independent
    directors  of  Price  Group  and the Price  Funds,  are  urged  to
    consider   the  reasons  for  the  adoption  of  this   Statement.
    Price   Group's  and  the  Price  Funds'  reputations   could   be
    adversely  affected  as the result of even  a  single  transaction
    considered  questionable  in  light of  the  fiduciary  duties  of
    the  Price  Advisers and the independent directors  of  the  Price
    Funds.

    Front  Running.   Front  Running  is  illegal.   It  is  generally
    defined  as  the  purchase or sale of a security  by  an  officer,
    director  or  employee  of an investment adviser  or  mutual  fund
    in  anticipation  of  and prior to the adviser  effecting  similar
    transactions  for  its clients in order to take  advantage  of  or
    avoid    changes   in   market   prices   effected    by    client
    transactions.
PERSONS  SUBJECT  TO  STATEMENT.  The  provisions  of  this  Statement
apply  as  described  below  to the following  persons  and  entities.
Each  person  and  entity  is classified as either  an  Access  Person
or  a  Non-Access  Person  as  described  below.   The  provisions  of
this  Statement  may  also apply to an Access Person's  or  Non-Access
Person's  spouse,  minor  children, and certain  other  relatives,  as
further  described  on  page  4-4 of this Statement.   Access  Persons
are  subject  to  all  provisions  of this  Statement  except  certain
restrictions  on  purchases  in initial public  offerings  that  apply
only  to  Investment  Personnel.  Non-Access Persons  are  subject  to
the   general   principles  of  the  Statement   and   its   reporting
requirements,  but  are  exempt  from  prior  clearance   requirements
except  for  transactions  in  Price Group  stock.   The  persons  and
entities covered by this Statement are:

    Price   Group.    Price  Group,  each  of  its  subsidiaries   and
    affiliates, and their retirement plans.

    Employee   Partnerships.   Partnerships  such  as   Pratt   Street
    Ventures.

    Personnel.    Each  officer,  inside  director  and  employee   of
    Price  Group  and  its subsidiaries and affiliates,  including  T.
    Rowe    Price    Investment   Services,   Inc.,   the    principal
    underwriter of the Price Funds.

    Certain Temporary Workers.  These workers include:

         All temporary workers hired on the Price Group payroll ("TRP
      Temporaries");

         All  agency  temporaries whose assignments  at  Price  Group
        exceed four weeks or whose cumulative assignments exceed eight
        weeks over a twelve-month period;

           All   independent  or  agency-provided  consultants  whose
        assignments  exceed four weeks or whose cumulative assignments
        exceed eight weeks over a twelve-month period and whose work is
        closely related to the ongoing work of Price Group's employees
        (versus project work that stands apart from ongoing work); and

       Any  contingent  worker whose assignment is more  than  casual
        in nature or who will be exposed to the kinds of information and
        situations that would create conflicts on matters covered in the
        Code.

    Retired   Employees.   Retired  employees  of  Price   Group   who
    continue  to  receive  investment research  information  from  one
    or   more   of  the  Price  Advisers  will  be  subject  to   this
    Statement.

    Independent  Directors  of  Price  Group,  the  Savings  Bank  and
    the  Price  Funds.   The  independent  directors  of  Price  Group
    include   those   directors  of  Price  Group  who   are   neither
    officers   nor   employees  of  Price  Group   or   any   of   its
    subsidiaries  or  affiliates.  The independent  directors  of  the
    T.   Rowe  Price  Savings  Bank  ("Savings  Bank")  include  those
    directors  of  the  Savings  Bank who  are  neither  officers  nor
    employees   of   Price  Group  or  any  of  its  subsidiaries   or
    affiliates.    The  independent  directors  of  the  Price   Funds
    include  those  directors of the Price Funds who  are  not  deemed
    to be "interested persons" of Price Group.

    Although  subject  to the general principles  of  this  Statement,
    including    the    definition    of    "beneficial    ownership,"
    independent  directors  are  subject only  to  modified  reporting
    requirements.   See  p.  4-17. The independent  directors  of  the
    Savings   Bank  and  the  Price  Funds  are  exempt   from   prior
    clearance  requirements.   The  independent  directors  of   Price
    Group  are  exempt  from the prior clearance  requirements  except
    for Price Group stock.

ACCESS  PERSONS.   Certain  persons and  entities  are  classified  as
"Access Persons" under the Code.  The term "Access Person" means:

       the Price Advisers;

        any  officer (vice president or above) or director (excluding
       independent directors) of any of the Price Advisers or the Price
       Funds;

        any  person  associated with Price Group or the  Price  Funds
       who, in connection with his or her regular functions or duties,
       makes, participates in, or obtains or has access to information
       regarding the purchase or sale of securities by a Price Fund or
       other advisory client, or whose functions relate to the making of
       any recommendations with respect to the purchases or sales; or

        any  person  in a control relationship to any  of  the  Price
       Advisers or a Price Fund who obtains or has access to information
       concerning recommendations made to a Price Fund or other advisory
       client with regard to the purchase or sale of securities by the
       Price Fund or advisory client.

   All   Access  Persons  are  notified  of  their  status  under  the
   Code.

    Investment  Personnel.   An Access Person  is  further  identified
    as  "Investment  Personnel"  if, in connection  with  his  or  her
    regular  functions  or  duties, he or she "makes  or  participates
    in  making  recommendations regarding  the  purchase  or  sale  of
    securities" by a Price Fund or other advisory client.

    The  term  "Investment Personnel" includes,  but  is  not  limited
    to:

       those   employees  who  are  authorized  to  make   investment
        decisions or to recommend securities transactions on behalf of
        the  firm's clients (investment counselors and members of  the
        mutual fund advisory committees);

        research and credit analysts; and

        traders who assist in the investment process.

    All  Investment  Personnel  are deemed Access  Persons  under  the
    Code.   All  Investment  Personnel are notified  of  their  status
    under    the    Code.    Investment   Personnel   are    generally
    prohibited  from  investing  in  initial  public  offerings.   See
    pp. 4-11; 4-13.

NON-ACCESS   PERSONS.     Persons  who  do   not   fall   within   the
definition  of  Access  Persons are deemed "Non-Access  Persons."   If
a  Non-Access  Person is married to an Access Person,  then  the  non-
Access   Person   is  deemed  to  be  an  Access  Person   under   the
beneficial ownership provisions described below.

QUESTIONS  ABOUT  THE  STATEMENT. You are urged  to  seek  the  advice
of  the  Chairperson  of  the Ethics Committee (U.S.-based  personnel)
or    the    TRP    International   Compliance   Team   (International
personnel)  when  you  have questions as to the  application  of  this
Statement to individual circumstances.

TRANSACTIONS  SUBJECT  TO STATEMENT.  Except as  provided  below,  the
provisions  of  this  Statement  apply  to  transactions   that   fall
under either one of the following two conditions:

First,  you  are  a  "beneficial owner"  of  the  security  under  the
Rule   16a-1  of  the  Securities  Exchange  Act  of  1934  ("Exchange
Act"), as defined below.

Second,  if  you  control  or direct securities  trading  for  another
person  or  entity,  those trades are subject to this  Statement  even
if   you   are  not  a  beneficial  owner  of  the  securities.    For
example,  if  you  have  an exercisable trading  authorization  (e.g.,
a  power  of  attorney  to  direct transactions  in  another  person's
account)  of  an  unrelated  person's or entity's  brokerage  account,
or   are   directing  another  person's  or  entity's  trades,   those
transactions  will  be subject to this Statement to  the  same  extent
your   personal  trades  would  be,  unless  exempted   as   described
below.

Definition  of  Beneficial  Owner.   A  "beneficial  owner"   is   any
person   who,   directly   or  indirectly,   through   any   contract,
arrangement,  understanding,  relationship,  or  otherwise,   has   or
shares  in  the  opportunity, directly or  indirectly,  to  profit  or
share in any profit derived from a transaction in the security.

A person has beneficial ownership in:

         securities held by members of the person's immediate  family
      sharing   the  same  household,  although  the  presumption   of
      beneficial ownership may be rebutted;

         a person's interest in securities held by a trust, which may
      include  both  trust beneficiaries or trustees  with  investment
      control;

         a  person's right to acquire securities through the exercise
      or  conversion  of  any  derivative  security,  whether  or  not
      presently exercisable;

         a  general partner's proportionate interest in the portfolio
      securities held by a general or limited partnership;

         certain  performance-related fees other than an  asset-based
      fee,  received  by any broker, dealer, bank, insurance  company,
      investment  company,  investment  adviser,  investment  manager,
      trustee or person or entity performing a similar function; and

         a person's right to dividends that is separated or separable
      from  the  underlying securities. Otherwise, right to  dividends
      alone shall not represent beneficial ownership in the securities.

A  shareholder  shall  not be deemed to have beneficial  ownership  in
the  portfolio  securities  held by a corporation  or  similar  entity
in  which  the  person  owns securities if the shareholder  is  not  a
controlling  shareholder of the entity and  does  not  have  or  share
investment control over the entity's portfolio.

Requests  for  Exemptions.   If you have  beneficial  ownership  of  a
security,  any  transaction involving that  security  is  presumed  to
be  subject  to  the  relevant requirements of this Statement,  unless
you  have  no  control  over the transaction.  Such  a  situation  may
arise,  for  example,  if you have delegated investment  authority  to
an   independent   investment  adviser,  or   your   spouse   has   an
independent   trading   program  in   which   you   have   no   input.
Similarly,  if  your  spouse  has  investment  control  over,  but  no
beneficial  ownership  in,  an unrelated  account,  an  exemption  may
be appropriate.

If   you   are  involved  in  an  investment  account  for  a   family
situation,  trust,  partnership, corporation,  etc.,  which  you  feel
should  not  be  subject  to the Statement's relevant  prior  approval
and/or   reporting   requirements,  you  should   submit   a   written
request   for   clarification  or  exemption   to   either   Baltimore
Legal/Compliance  or  the  TRP  International  Compliance   Team,   as
appropriate.    Any  such  request  for  clarification  or   exemption
should   name   the  account,  your  interest  in  the  account,   the
persons  or  firms  responsible  for its  management,  and  the  basis
upon  which  the  exemption  is  being claimed.   Exemptions  are  not
self-executing;  any  exemption  must  be  granted  through  Baltimore
Legal/Compliance or the TRP International Compliance Team.

PRIOR   CLEARANCE  REQUIREMENTS  GENERALLY.   As  described,   certain
transactions  require  prior  clearance before  execution.   Receiving
prior   clearance   does   not  relieve  you  from   conducting   your
personal   securities  transactions  in  full  compliance   with   the
Code,  including  its prohibition on trading while  in  possession  of
material,  inside  information,  and with  applicable  law,  including
the  prohibition  on  Front Running (see page 4-1  for  definition  of
Front Running).

TRANSACTIONS  IN  STOCK  OF PRICE GROUP.  Because  Price  Group  is  a
public   company,  ownership  of  its  stock  subjects  its  officers,
inside   and   independent  directors,  employees   and   all   others
subject   to  the  Code  to  special  legal  requirements  under   the
federal   securities  laws.   You  are  responsible   for   your   own
compliance   with  these  requirements.   In  connection  with   these
legal  requirements,  Price  Group has  adopted  the  following  rules
and procedures:

    Independent   Directors   of   Price   Funds.    The   independent
    directors  of  the  Price  Funds are prohibited  from  owning  the
    stock of Price Group.

    Quarterly  Earnings  Report.  Generally, all  Access  Persons  and
    Non-Access  Persons  and  the  independent  directors   of   Price
    Group   must  refrain  from  initiating  transactions   in   Price
    Group  stock  in  which they have a beneficial interest  from  the
    sixth  trading  day  following the end of  the  quarter  (or  such
    other  date  as  management shall from  time  to  time  determine)
    until  the  third  trading day following  the  public  release  of
    earnings.   You  will  be notified in writing through  the  Office
    of  the  Secretary  of  Price  Group ("Secretary")  from  time  to
    time as to the controlling dates.

    Prior  Clearance  of  Price  Group Stock  Transactions  Generally.
    Access   Persons  and  Non-Access  Persons  and  the   independent
    directors   of  Price  Group  are  required  to  obtain  clearance
    prior  to  effecting  any  proposed transaction  (including  gifts
    and  transfers)  involving  shares  of  Price  Group  stock  owned
    beneficially  or  through the Employee  Stock  Purchase  Plan.   A
    transfer  includes  a  change  in  ownership  name  of  shares  of
    Price  Group  stock,  including a  transfer  of  the  shares  into
    street   name  to  be  held  in  a  securities  account  and   any
    transfers  of  shares  of  Price Group  stock  between  securities
    firms or accounts, including accounts held at the same firm.

    Prior  Clearance  Procedures  for  Price  Group  Stock.   Requests
    for  prior  clearance  must be in writing  on  the  form  entitled
    "Notification  of  Proposed  Transaction"  (available   from   the
    Corporate  Records  Department and on the  firm's  Intranet  under
    Corporate/Corporate   Records)   and   be   submitted    to    the
    Secretary,  who  is  responsible for  processing  and  maintaining
    the  records  of  all  such  requests.   This  includes  not  only
    market  transactions,  but also sales of  stock  purchased  either
    through  the  Price  Group Employee Stock Purchase  Plan  ("ESPP")
    or  through  a  brokerage account if shares of Price  Group  stock
    are   transferred   there  from  the  ESPP.   Purchases   effected
    through the ESPP are automatically reported to the Secretary.

    Prohibition   Regarding  Transactions  in  Publicly-Traded   Price
    Group   Options.   Transactions  in  publicly-traded  options   on
    Price Group stock are not permitted.

    Applicability    of   60-Day   Rule   to   Price    Group    Stock
    Transactions.   Transactions  in Price  Group  stock  are  subject
    to  the  60-Day  Rule  except  for transactions  effected  through
    the  ESPP,  the  exercise  of employee stock  options  granted  by
    Price   Group,   and  shares  obtained  through   an   established
    dividend  reinvestment program.  The 60-Day  Rule  does  apply  to
    shares  transferred  out  of the ESPP  to  a  securities  account;
    generally,  however, an employee remaining in  the  ESPP  may  not
    transfer shares held less than 60 days out of the ESPP.

    Gifts   of   Price   Group  stock,  although  subject   to   prior
    clearance, are also not subject to this Rule.

    Purchases  through  payroll deduction  of  Price  Group  stock  in
    the  ESPP  are  not  considered in determining  the  applicability
    of   the  60-Day  Rule  to  market  transactions  in  Price  Group
    stock. See p. 4-22.



         Access Persons and Non-Access Persons and the
         independent directors of Price Group must obtain
         prior clearance of any transaction involving Price
         Group stock from the Office of the Secretary of Price
         Group.

    Initial  Disclosure of Holdings of Price Group  Stock.   Each
    new employee must report to the Secretary any shares of Price
    Group  stock  of which he or she has beneficial ownership  no
    later than 10 days after his or her starting date.

    Dividend Reinvestment Plans for Price Group Stock.  Purchases
    of  Price  Group stock owned outside of the ESPP and effected
    through  a dividend reinvestment plan need not receive  prior
    clearance  if  the firm has been previously notified  by  the
    employee  that he or she will be participating in that  plan.
    Reporting  of  transactions effected through that  plan  need
    only  be made quarterly, except in the case of employees  who
    are  subject to Section 16 of the Securities Exchange Act  of
    1934, who must report such transactions at least monthly.

    Effectiveness  of  Prior  Clearance.   Prior   clearance   of
    transactions in Price Group stock is effective for  five  (5)
    business  days from and including the date the  clearance  is
    granted,  unless (i) advised to the contrary by the Secretary
    prior  to  the  proposed  transaction,  or  (ii)  the  person
    receiving  the  approval comes into possession  of  material,
    non-public information concerning the firm.  If the  proposed
    transaction in Price Group stock is not executed within  this
    time  period,  a  new clearance must be obtained  before  the
    individual can execute the proposed transaction.

    Reporting  of Disposition of Proposed Transaction.  You  must
    use  the form returned to you by the Secretary to notify  the
    Secretary   of   the   disposition  (whether   the   proposed
    transaction   was  effected  or  not)  of  each   transaction
    involving  shares of Price Group stock owned  directly.   The
    notice  must  be  returned within two business  days  of  the
    trade's execution, or within seven business days of the  date
    of prior clearance if the trade is not executed.

    Insider  Reporting  and  Liability.   Under  current   rules,
    certain  officers,  directors  and  10%  stockholders  of   a
    publicly  traded  company ("Insiders")  are  subject  to  the
    requirements  of Section 16. Insiders include  the  directors
    and certain managing directors of Price Group.

    SEC   Reporting.   There  are  three  reporting  forms  which
    Insiders  are  required to file with the SEC to report  their
    purchase, sale and transfer transactions in, and holdings of,
    Price  Group  stock.   Although the  Secretary  will  provide
    assistance  in  complying  with  these  requirements  as   an
    accommodation   to   Insiders,   it   remains    the    legal
    responsibility of each Insider to assure that the  applicable
    reports are filed in a timely manner.

           Form 3.  The initial ownership report by an Insider is
          required to be filed on Form 3.  This report must be filed within
          ten days after a person becomes an Insider (i.e., is elected as a
          director or appointed as an executive officer) to report all
          current holdings of Price Group stock.  Following the election or
          appointment of an Insider, the Secretary will deliver to the
          Insider a Form 3 for appropriate signatures and will file the
          form with the SEC.

           Form 4.  Any change in the Insider's ownership of Price
          Group stock must be reported on a Form 4 unless eligible for
          deferred reporting on year-end Form 5.  The Form 4 is due by the
          10th day following the end of the month in which the ownership
          change occurred. Following receipt of the Notice of Disposition
          of the proposed transaction, the Secretary will deliver to the
          Insider a Form 4, as applicable, for appropriate signatures and
          will file the form with the SEC.

           Form 5.  Any transaction or holding that is exempt from
          reporting on Form 4, such as small purchases of stock, gifts,
          etc. may be reported on a deferred basis on Form 5 within 45 days
          after the end of the calendar year in which the transaction
          occurred. No Form 5 is necessary if all transactions and holdings
          were previously reported on Form 4.

        Liability  for  Short-Swing Profits.   Under  the  United
        States   securities  laws,  profit  realized  by  certain
        officers, as well as directors and 10% stockholders of  a
        company (including Price Group) as a result of a purchase
        and  sale (or sale and purchase) of stock of the  company
        within  a period of less than six months must be returned
        to the firm or its designated payee upon request.

    Office  of  Thrift Supervision ("OTS") Reporting.   TRPA  and
    Price  Group  are holding companies of T. Rowe Price  Savings
    Bank, which is regulated by the OTS.  OTS regulations require
    the Directors and senior officers of TRPA and Price Group  to
    file  reports regarding their personal holdings of the  stock
    of  Price Group and of the stock of any non-affiliated  bank,
    savings  bank,  bank  holding company, or  savings  and  loan
    holding company.  Although the Bank's Compliance Officer will
    provide assistance in complying with these requirements as an
    accommodation, it remains the responsibility of  each  person
    to  ensure  that the required reports are filed in  a  timely
    manner.

PRIOR  CLEARANCE REQUIREMENTS (OTHER THAN PRICE GROUP STOCK)  FOR
ACCESS PERSONS.

All Access Persons must obtain prior clearance before directly or
indirectly  initiating, recommending, or in any way participating
in, the purchase or sale of a security in which the Access Person
has, or by reason of such transaction may acquire, any beneficial
interest or which he or she controls, unless exempted below.  Non-
Access  Persons are not required to obtain prior clearance before
engaging  in any securities transactions, except for transactions
in Price Group stock.


         Access Persons and Non-Access Persons and the
         independent directors of Price Group must obtain
         prior clearance of any transaction involving Price
         Group stock from the Office of the Secretary of Price
         Group.


Where  required, prior clearance must be obtained  regardless  of
whether   the  transaction  is  effected  through  TRP  Brokerage
(generally  available  only  to U.S.  residents)  or  through  an
unaffiliated broker/dealer or other entity. Please note that  the
prior  clearance procedures do not check compliance with the  60-
Day  Rule  (p.  4-21);  you  are responsible  for  ensuring  your
compliance with this rule.

TRANSACTIONS  (OTHER THAN IN PRICE GROUP STOCK) THAT  ARE  EXEMPT
FROM  PRIOR  CLEARANCE AND REPORTING.  The following transactions
are   exempt   from  both  the  prior  clearance  and   reporting
requirements:

        Mutual  Funds  and  Variable  Insurance  Products.    The
        purchase   or  redemption  of  shares  of  any   open-end
        investment  companies, including  the  Price  Funds,  and
        variable insurance products, except that any employee who
        serves as the president or executive vice president of  a
        Price Fund must report his or her beneficial ownership or
        control   of   shares   in   that   Fund   to   Baltimore
        Legal/Compliance through electronic mail to Dottie Jones.

        U.S.  Government  Obligations.   Purchases  or  sales  of
        direct obligations of the U.S. Government.

        Certain Commodity Futures Contracts.  Purchases or  sales
        of  commodity futures contracts for tangible goods (e.g.,
        corn,  soybeans, wheat) if the transaction  is  regulated
        solely  by  the  United States Commodity Futures  Trading
        Commission  ("CFTC").   Futures contracts  for  financial
        instruments, however, must receive prior clearance.

TRANSACTIONS (OTHER THAN PRICE GROUP STOCK) THAT ARE EXEMPT  FROM
PRIOR CLEARANCE, BUT MUST BE REPORTED BY BOTH ACCESS PERSONS  AND
NON-ACCESS PERSONS.

        Unit Investment Trusts.  Purchases or sales of shares  in
        unit  investment  trusts, including such unit  investment
        trusts  as DIAMONDS, SPYDER and Nasdaq-100 Index Tracking
        Stock ("QQQ").

        National   Government  Obligations  (other  than   U.S.).
        Purchases or sales of direct obligations of national (non-
        U.S.) governments.

        Pro   Rata  Distributions.   Purchases  effected  by  the
        exercise  of rights issued pro rata to all holders  of  a
        class of securities or the sale of rights so received.

        Stock  Splits and Similar Acquisitions.  The  acquisition
        of  additional  shares  of  existing  corporate  holdings
        through  stock  splits,  stock  dividends,  exercise   of
        rights,  exchange  or  conversion.   Reporting  of   such
        transactions need only be made quarterly.

        Mandatory  Tenders.   Purchases and sales  of  securities
        pursuant to a mandatory tender offer.

        Spousal   Employee-Sponsored  Payroll  Deduction   Plans.
        Purchases  by  an Access Person's spouse pursuant  to  an
        employee-sponsored payroll deduction plan (e.g., a 401(k)
        plan or employee stock purchase plan), provided Baltimore
        Legal/Compliance  (U.S.-based  personnel)  or   the   TRP
        International  Compliance Team (International  personnel)
        has  been  previously notified by the Access Person  that
        the spouse will be participating in the payroll deduction
        plan.   Reporting of such transactions need only be  made
        quarterly.

        Exercise of Stock Option of Corporate Employer by Spouse.
        Transactions involving the exercise by an Access Person's
        spouse  of  a  stock  option issued  by  the  corporation
        employing the spouse.  However, a subsequent sale of  the
        stock  obtained  by  means of the exercise  must  receive
        prior clearance.

        Dividend Reinvestment Plans.  Purchases effected  through
        an   established  Dividend  Reinvestment  Plan   ("DRP").
        Reporting of these transactions may be made quarterly. An
        Access  Person's purchase of share(s) of  the  issuer  to
        initiate  participation in the DRP or an Access  Person's
        purchase  of  shares in addition to those purchased  with
        dividends (a "Connected Purchase") and any sale of shares
        from the DRP must receive prior clearance.

        Systematic  Investment Plans/Savings Schemes.   Purchases
        effected  through a systematic investment plan  (i.e.,  a
        regular  savings  scheme or savings plan)  involving  the
        automatic  investment of a set dollar or  other  currency
        amount   on   predetermined  dates,  provided   Baltimore
        Legal/Compliance  (U.S.-based  personnel)  or   the   TRP
        International  Compliance Team (International  personnel)
        has been previously notified by the Access Person that he
        or  she  will  be  participating in the plan  or  scheme.
        Reporting  of  Systematic Investment Plan/Savings  Scheme
        transactions  need  only be made  quarterly.   An  Access
        Person's purchase of securities of the issuer to initiate
        participation  in the plan and any sale  of  shares  from
        such a plan must receive prior clearance.

        Inheritances.   The  acquisition  of  securities  through
inheritance.

        Gifts.  The giving of or receipt of a security as a gift.

OTHER  TRANSACTION REPORTING REQUIREMENTS.  Any transaction  that
is subject to the prior clearance requirements prior to execution
on  behalf  of an Access Person, including purchases  in  initial
public  offerings  and  private placement transactions,  must  be
reported.   Although  Non-Access  Persons  are  not  required  to
receive  prior clearance for securities transactions (other  than
Price  Group stock), they must report any transaction that  would
have been required to be prior cleared by an Access Person.

PROCEDURES FOR OBTAINING PRIOR CLEARANCE (OTHER THAN PRICE  GROUP
STOCK) FOR ACCESS PERSONS.  Unless described as exempt from prior
clearance  above  or  subject  to an  exemption  granted  by  the
Chairperson of the Ethics Committee, Access Persons must  receive
prior  clearance for all securities transactions.  This  includes
transactions in

     closed-end funds, including Exchange Traded Funds  ("ETFs")
  (e.g., iShares; Cubes), and
    sector index funds that are closed-end funds.

All  Access Persons should follow the procedures set forth below,
depending   upon   their  location,  before   engaging   in   the
transactions described.

For U.S. - Based Access Persons:

     Procedures For Obtaining Prior Clearance For Initial  Public
   Offerings ("IPOs"):

        Non-Investment  Personnel.  Access Persons  who  are  not
        Investment  Personnel  ("Non-Investment  Personnel")  may
        purchase  securities that are the subject of an IPO  only
        if  prior  written  approval has been obtained  from  the
        Chairperson  of  the  Ethics  Committee  or  his  or  her
        designee   ("Designee").   An  IPO  is  an  offering   of
        securities  registered under the Securities Act  of  1933
        when the issuer of the securities, immediately before the
        registration,  was  not  subject  to  certain   reporting
        requirements of the Securities Exchange Act of 1934.

        In   considering  such  a  request  for   approval,   the
        Chairperson or his or her Designee will determine whether
        the  proposed transaction presents a conflict of interest
        with any of the firm's clients or otherwise violates  the
        Code.   The Chairperson or his or her Designee will  also
        determine whether the following conditions have been met:

        1.   The purchase is made through the Non-Investment Personnel's
           regular broker;

        2.   The number of shares to be purchased is commensurate with
           the normal size and activity of the Non-Investment Personnel's
           account; and

        3.   The transaction otherwise meets the requirements of the
           NASD's rules on free riding and withholding.

    Non-Investment  Personnel will not be permitted  to  purchase
    shares  in an IPO if any of the firm's clients are prohibited
    from  doing  so.   Therefore, even after  approval  has  been
    obtained from the Chairperson of the Ethics Committee or  his
    or her Designee, Non-Investment Personnel must check with the
    Equity  Trading  Desk the day the offering is  priced  before
    purchasing in the IPO. This prohibition will remain in effect
    until the firm's clients have had the opportunity to purchase
    in the secondary market once the underwriting is completed --
    commonly  referred to as the aftermarket.   The  60-Day  Rule
    applies to transactions in securities purchased in an IPO.

        Investment  Personnel.   Investment  Personnel  may   not
        purchase securities in an IPO.

        Non-Access Persons.  Although Non-Access Persons are  not
        required  to  receive prior clearance  before  purchasing
        shares  in  an  IPO,  any  Non-Access  Person  who  is  a
        registered  representative  of  Investment  Services   is
        reminded that NASD rules may restrict his or her  ability
        to buy shares in a "hot issue," which is a new issue that
        trades at a premium in the secondary market whenever that
        trading commences.

    Procedures   For  Obtaining  Prior  Clearance   For   Private
    Placements.  Access  Persons may  not  invest  in  a  private
    placement  of securities, including the purchase  of  limited
    partnership interests, unless prior written approval has been
    obtained  from the Chairperson of the Ethics Committee  or  a
    Designee.   In  considering such a request for approval,  the
    Chairperson will determine whether the investment opportunity
    (private  placement)  should  be  reserved  for  the   firm's
    clients, and whether the opportunity is being offered to  the
    Access Person by virtue of his or her position with the firm.
    The   Chairperson  will  also  secure,  if  appropriate,  the
    approval of the proposed transaction from the chairperson  of
    the applicable investment steering committee.

        Continuing   Obligation.   An  Access  Person   who   has
        received  approval  to invest in a private  placement  of
        securities   and  who,  at  a  later  date,   anticipates
        participating  in the firm's investment decision  process
        regarding  the  purchase or sale  of  securities  of  the
        issuer  of  that  private  placement  on  behalf  of  any
        client,  must  immediately  disclose  his  or  her  prior
        investment  in  the private placement to the  Chairperson
        of  the  Ethics Committee and to the chairperson  of  the
        appropriate investment steering committee.

   Registered   representatives  of   Investment   Services   are
   reminded that NASD rules may restrict investment in a  private
   placement in certain circumstances.

    Procedures  For  Obtaining  Prior  Clearance  For  All  Other
    Securities  Transactions.  Requests for  prior  clearance  by
    Access   Persons   for  all  other  securities   transactions
    requiring prior clearance should generally be made via iTrade
    on  the  firm's  intranet to the Equity  Trading  Department,
    which will be responsible for processing and maintaining  the
    records  of  all such requests.  If iTrade is not  available,
    requests  may  be made orally, in writing, or  by  electronic
    mail (e-mail address "Personal Trades" in the electronic mail
    address  book).   Obtaining clearance by electronic  mail  if
    iTrade  is not available is strongly encouraged. All requests
    must  include the name of the security, the number of  shares
    or   amount  of  bond  involved,  and  the  nature   of   the
    transaction,  i.e., whether the transaction  is  a  purchase,
    sale, short sale, or buy to cover.  Responses to all requests
    will  be  made  by  iTrade or the Equity Trading  Department,
    documenting the request and its approval/disapproval.

    Requests will normally be processed on the same day; however,
    additional  time  may  be  required for  prior  clearance  of
    transactions in non-U.S. securities.

    Effectiveness  of  Prior Clearance.   Prior  clearance  of  a
    securities  transaction is effective for three  (3)  business
    days  from  and including the date the clearance is  granted,
    regardless of the time of day when clearance is granted.   If
    the  proposed  securities transaction is not executed  within
    this  time,  a new clearance must be obtained.  In situations
    where  it appears that the trade will not be executed  within
    three business days even though the order was entered in that
    time  period  (e.g.,  certain transactions  through  Transfer
    Agents   or   spousal  employee-sponsored  payroll  deduction
    plans), please contact Baltimore Legal/Compliance.

    Reminder.   If  you  are  an Access  Person  and  become  the
    beneficial  owner of another's securities (e.g., by  marriage
    to the owner of the securities) or begin to direct trading of
    another's  securities, then transactions in those  securities
    become subject to the prior clearance requirements.

For International Access Persons:

    General Procedures For Obtaining Prior Clearance (Other  Than
    Price  Group Stock) For Access Persons.  Requests  for  prior
    clearance  may be made by electronic mail or by submitting  a
    written  form to the TRP International Compliance  Team.  The
    TRP   International  Compliance  Team  is   responsible   for
    processing and maintaining the records of all such  requests.
    All  requests  must  include the name of  the  security,  the
    number  of  shares  or  amount  of  bond  involved,  and  the
    estimated value of the requested transaction.

    The TRP International Compliance Team will record whether the
    request was approved or disapproved and the date and time  of
    the  approval or disapproval; the reason for any disapproval;
    the  nature of the transaction (i.e., whether the transaction
    is  a  purchase,  sale, short sale, or  buy  to  cover),  and
    whether  the  securities are part of a new issue  or  private
    placement.

    Responses  to  all  requests will be  confirmed  by  the  TRP
    International  Compliance Team by electronic  mail  or  on  a
    standard  written  form  documenting  the  request  and   its
    approval/disapproval.

    Requests will normally be processed on the same day they  are
    received; however, additional time may be required  to  allow
    checks to be made with overseas offices.

    Effectiveness  of  Prior Clearance.   Prior  clearance  of  a
    securities  transaction is effective for three  (3)  business
    days  from  and including the date the clearance is  granted.
    If the proposed securities transaction is not executed within
    this time, a new clearance must be obtained.  For example, if
    approval  is  granted at 2:00 pm Monday, the  trade  must  be
    executed  by Wednesday.  In situations where it appears  that
    the  trade  will not be executed within three  business  days
    even  though the order was entered in that time period (e.g.,
    an  Individual  Savings  Account),  please  contact  the  TRP
    International Compliance Team.

    Procedures  for Obtaining Prior Clearance for Initial  Public
    Offerings ("IPOs"):

    Investment Personnel.  Generally Investment Personnel may not
    purchase shares in an IPO. However, an exemption from the TRP
    International Compliance Team to permit investment in certain
    IPOs open to the general public in which allocations are made
    by the issuer/syndicate on a purely random basis (lottery) or
    on a pro-rata basis per application ("Pro-Rata Offering") may
    be available.

      Non-Investment  Personnel.   Access  Persons   other   than
Investment Personnel ("Non-
    Investment Personnel") may purchase securities in a  Pro-rata
    Offering if the following four conditions are met:

            The issue is a Pro-Rata Offering;

            Residence;

            No order for the purchase of any such securities has been
          entered by a Price Adviser on behalf of any client; and

            The number of shares to be purchased is commensurate with
          the normal size and activity of the Access Person's account.

   Non-Investment  Personnel  may also  be  granted  approval  to
   purchase  securities that are the subject  of  a  non-Pro-Rata
   Offering.   In  considering such a request for  approval,  the
   TRP  International Compliance Team will determine whether  the
   proposed transaction presents a conflict of interest with  any
   of   the  firm's  clients  or  otherwise  violates  the  Code.
   Approvals will carry the following conditions:

            1.  The  purchase  is made through the Non-Investment
                Personnel's  regular  broker,  bank,  or  from  a
                syndicate  member through a general  solicitation
                or subscription form, if relevant; and

            2.  The   number   of  shares  to  be  purchased   is
                commensurate with the normal size and activity of
                the Non-Investment Personnel's account.

    All  Access Persons.  Neither Investment Personnel  nor  Non-
    Investment Personnel will be permitted to purchase in an  IPO
    if  any  of  the Price Advisers' clients are prohibited  from
    doing so.  This prohibition will remain in effect until these
    clients have had the opportunity to purchase in the secondary
    market   once  the  underwriting  is  completed  --  commonly
    referred to as the aftermarket.  In addition, the 60-Day Rule
    applies to transactions in securities purchased in an IPO.

    Procedures   for  Obtaining  Prior  Clearance   for   Private
    Placements.   Approval for an Access Person to invest  in  or
    sell  securities through a private placement  of  securities,
    including the purchase of limited partnership interests, must
    be  sought from the TRP International Compliance Team in  the
    usual manner. The approval process will include a review by a
    member  of  the  Investment  Team to  determine  whether  the
    investment opportunity (private placement) should be reserved
    for  the firm's clients and whether the opportunity is  being
    offered to the Access Person by virtue of his or her position
    with  the firm, as well as approval by a member of the Ethics
    Committee.

        Continuing  Obligation.   Any  Access  Person   who   has
        received  approval  to invest in a private  placement  of
        securities   and  who,  at  a  later  date,   anticipates
        participating  in the firm's investment decision  process
        regarding  the  purchase or sale  of  securities  of  the
        issuer of that private placement on behalf of any client,
        must immediately disclose his or her prior investment  in
        the private placement to the TRP International Compliance
        Team.

REASONS  FOR  DISALLOWING ANY PROPOSED TRANSACTION.   A  proposed
securities  transaction  will  be  disapproved  by  the   Trading
Department,  either  directly  or  by  iTrade,  and/or   by   the
Chairperson  of the Ethics Committee or by the TRP  International
Compliance  Team  (unless it is determined that an  exemption  is
appropriate), if:


       Pending Client Orders.  Orders have been placed by any  of
       the Price Advisers to purchase or sell the security.

       Purchases  and Sales Within Seven (7) Calendar Days.   The
       security  has been purchased or sold by any  client  of  a
       Price  Adviser  within  seven  calendar  days  immediately
       prior  to  the  date  of  the proposed  transaction.   For
       example,  if  a  client transaction occurs on  Monday,  an
       Access  Person  may  not purchase or  sell  that  security
       until Tuesday of the following week.  If all clients  have
       eliminated  their holdings in a particular  security,  the
       seven-day  restriction  is not  applicable  to  an  Access
       Person's transactions in that security.

       Approved  Company Rating Changes.  A change in the  rating
       of  an  approved company as reported in the  firm's  Daily
       Research News has occurred within seven (7) calendar  days
       immediately   prior   to   the  date   of   the   proposed
       transaction.  Accordingly, trading would not be  permitted
       until the eighth (8) calendar day.

       Securities Subject to Internal Trading Restrictions.   The
       security  is  limited or restricted by any  of  the  Price
       Advisers as to purchase or sale by Access Persons.

If for any reason an Access Person has a proposed securities
transaction disapproved, he or she must not communicate any
information about the disapproval to another person and must not
cause any other person to enter into such a transaction.

Requests  for Waivers of Prior Clearance Denials.  If  an  Access
Person's request for prior clearance has been denied, he  or  she
may  apply  to  the  Chairperson of the Ethics  Committee  for  a
waiver.   All  such requests must be in writing  and  must  fully
describe  the  basis  upon which the waiver is  being  requested.
Waivers are not routinely granted.

TRANSACTION  CONFIRMATIONS AND PERIODIC ACCOUNT STATEMENTS.   All
Access    Persons   and   Non-Access   Persons    must    request
broker-dealers,  investment advisers, banks, or  other  financial
institutions  executing their transactions to  send  a  duplicate
confirmation  or  contract note with respect to  each  and  every
reportable transaction, including Price Group stock, and  a  copy
of  all periodic statements for all securities accounts in  which
the  Access  Person  or Non-Access Person is considered  to  have
beneficial  ownership  and/or  control  (see  page  4-4   for   a
discussion  of  beneficial  ownership and  control  concepts)  as
follows:

     U.S.-based personnel should have this information  sent  to
  the  attention of Compliance, Legal Department, T. Rowe  Price,
  P.O. Box 17218, Baltimore, Maryland  21297-1218.

    International personnel should have this information sent to
  the attention of the TRP International Compliance Team, T. Rowe
  Price International, Inc., 60 Queen Victoria Street, London EC4N
  4TZ United Kingdom.

NOTIFICATION OF SECURITIES ACCOUNTS.  All Access Persons and Non-
Access  Persons must give notice before opening or trading  in  a
securities  account with any broker, dealer, investment  adviser,
bank, or other financial institution, including TRP Brokerage, as
follows:

      U.S.-based  personnel  must  give  notice  by  e-mail   to
  Legal/Compliance;

     International personnel must give notice in writing  (which
  may include e-mail) to the TRP International Compliance Team.

    New  Personnel Subject to the Code.  A person subject to  the
    Code  must  give  written notice as  directed  above  of  any
    existing  securities  accounts maintained  with  any  broker,
    dealer,   investment   adviser,  bank  or   other   financial
    institution within 10 days of association with the firm.

    You  do  not  have to report accounts at transfer  agents  or
    similar entities if the only securities in those accounts are
    variable insurance products or mutual funds if these are  the
    only  types of securities that can be held or traded  in  the
    accounts.   If  other securities can be held or  traded,  the
    accounts  must  be reported.  For example,  if  you  have  an
    account  at  T.  Rowe Price Services, Inc., a transfer  agent
    that  holds  shares  of a Price Fund,  that  account  is  not
    reportable.   If,  however, you have a brokerage  account  it
    must  be reported even if the only securities currently  held
    or traded in it are mutual funds.

    Officers,   Directors  and  Registered   Representatives   of
    Investment  Services.   The  NASD  requires  each  associated
    person of T. Rowe Price Investment Services, Inc. to:

        Obtain  approval from Investment Services  (whether  the
       registered  person  is  based  in  the  United  States  or
       internationally) -- the request should be in writing, directed to
       Baltimore Legal/Compliance, and submitted before opening or
       placing the initial trade in a securities account; and

       If the securities account is with a broker/dealer, provide
       the broker/dealer with written notice of his or her association
       with Investment Services.

   Annual  Statement by Access Persons.  Each Access Person  must
   also file with the firm a statement of his or her accounts  as
   of year-end in January of the following year.

   Reminder.   If  you become the beneficial owner  of  another's
   securities  (e.g., by marriage to the owner of the securities)
   or  begin to direct trading of another's securities, then  the
   associated  securities accounts become subject to the  account
   reporting requirements.

PROCEDURES    FOR   REPORTING   TRANSACTIONS.    The    following
requirements apply both to Access Persons and Non-Access Persons:

    Report  Form.  If the executing firm provides a confirmation,
    contract note or similar statement directly to the firm,  you
    do not need to make a further report.  All other transactions
    must  be  reported  on  the form designated  "T.  Rowe  Price
    Employee's  Report  of  Securities  Transactions,"  which  is
    available on the firm's Intranet under Corporate/Legal.

    When   Reports  are  Due.   You  must  report  a   securities
    transaction  within ten (10) days after  the  trade  date  or
    within  (10)  days  after the date on which  you  first  gain
    knowledge of the transaction (for example, a bequest) if this
    is  later.   Reporting of transactions involving a systematic
    investment  plan/savings scheme, in an  established  dividend
    reinvestment plan, or the purchase of securities by a  spouse
    pursuant  to  an  employee-sponsored payroll deduction  plan,
    however, may be reported quarterly.

    The  TRP  International Compliance Team will send all reports
    it  receives  to  Baltimore Legal/Compliance on  a  quarterly
    basis.

    Reminder.   If  you become the beneficial owner of  another's
    securities (e.g., by marriage to the owner of the securities)
    or  begin  to  direct  trading of another's  securities,  the
    transactions  in  these  securities  become  subject  to  the
    transaction reporting requirements.

TRANSACTION REPORTING REQUIREMENTS FOR THE INDEPENDENT  DIRECTORS
OF  THE  PRICE  FUNDS, THE INDEPENDENT DIRECTORS OF PRICE  GROUP,
AND   THE  INDEPENDENT  DIRECTORS  OF  THE  SAVINGS  BANK.    The
independent directors of the Price Funds are subject to the  same
reporting  requirements as Access Persons and Non-Access  Persons
except  that reports need only be filed quarterly.  Specifically:
(1)  a report for each securities transaction must be filed  with
Baltimore/Legal Compliance no later than ten (10) days after  the
end  of  the  calendar  quarter  in  which  the  transaction  was
effected;  and  (2)  a  report must be filed  for  each  quarter,
regardless   of   whether   there  have   been   any   reportable
transactions.    Baltimore/Legal   Compliance   will   send   the
independent  directors of the Price Funds a reminder  letter  and
reporting  form approximately ten days prior to the end  of  each
calendar quarter.

The  independent  directors of Price Group are  not  required  to
report   their  personal  securities  transactions  (other   than
transactions in Price Group stock) as long as they do not  obtain
information  about  the  Price  Advisers'  investment   research,
recommendations,  or  transactions.   However,  the   independent
directors  of  Price Group are reminded that changes  to  certain
information  reported by the respective independent  director  in
the  Annual Questionnaire for Independent Directors are  required
to  be reported to Baltimore/Corporate Records (e.g., changes  in
holdings   of  stock  of  financial  institutions  or   financial
institution holding companies).

The independent directors of the Savings Bank are not required to
report their personal securities transactions except as they  may
be  specifically  requested from time to time to  do  so  by  the
Savings   Bank  in  accordance  with  regulatory  or  examination
requirements.

MISCELLANEOUS RULES REGARDING PERSONAL SECURITIES TRANSACTIONS.
These rules vary in their applicability depending upon whether
you are an Access Person.

The  following  rules apply to all Access Persons and  Non-Access
Persons  and,  where indicated, to the independent  directors  of
Price Group and the Price Funds.

    Dealing with Clients.  Access Persons, Non-Access Persons and
    the  independent directors of Price Group and the Price Funds
    may  not, directly or indirectly, sell to or purchase from  a
    client any security.  Market transactions are not subject  to
    this  restriction.  This prohibition does  not  preclude  the
    purchase or redemption of shares of any mutual fund that is a
    client  of  any of the Price Advisers and does not  apply  to
    transactions   in   a   spousal  employer-sponsored   payroll
    deduction  plan  or spousal employer-sponsored  stock  option
    plan.

    Client Investment Partnerships.

        Co-Investing.   The independent directors  of  the  Price
        Funds are not permitted to co-invest in client investment
        partnerships  of Price Group or its affiliates,  such  as
        Strategic Partners, Threshold, and Recovery.

        Direct  Investment.   The independent  directors  of  the
        Price  Funds  are  not  permitted to  invest  as  limited
        partners in client investment partnerships of Price Group
        or its affiliates.

    Investment Clubs.  These restrictions vary depending upon the
    person's status, as follows:

        Non-Access  Persons.  A Non-Access  Person  may  form  or
        participate  in  a  stock  or  investment  club   without
        approval  of  the  Chairperson of  the  Ethics  Committee
        (U.S.-based   personnel)   or   the   TRP   International
        Compliance    Team   (international   personnel).    Only
        transactions  in Price Group stock are subject  to  prior
        clearance  requirements.   Club  transactions   must   be
        reported  just  as  the  Non-Access  Person's  individual
        trades are reported.

        Access  Persons.   An  Access  Person  may  not  form  or
        participate  in a stock or investment club  unless  prior
        written  approval has been obtained from the  Chairperson
        of  the  Ethics Committee (U.S.-based personnel)  or  the
        TRP    International   Compliance   Team   (international
        personnel).   All  transactions  by  such  a   stock   or
        investment  club in which an Access Person has beneficial
        ownership  or  control  are subject  to  the  same  prior
        clearance  and  reporting requirements applicable  to  an
        individual Access Person's trades.

        If,  however, the Access Person has beneficial  ownership
        solely by virtue of his or her spouse's participation  in
        the  club  and  has no investment control or  input  into
        decisions  regarding the club's securities  transactions,
        he  or  she  may  request the waiver of  prior  clearance
        requirements  of  the  club's  transactions  (except  for
        transactions  in Price Group stock) from the  Chairperson
        of   the   Ethics  Committee  or  the  TRP  International
        Compliance Team, as appropriate, as part of the  approval
        process.

    Margin Accounts.  While margin accounts are discouraged,  you
    may  open  and maintain margin accounts for the  purchase  of
    securities  provided such accounts are with firms with  which
    you maintain a regular securities account relationship.

    Trading  Activity.  You are discouraged from  engaging  in  a
    pattern of securities transactions which either:

            Is so excessively frequent as to potentially impact your
           ability to carry out your assigned responsibilities, or

            Involves securities positions that are disproportionate to
          your net assets.

        At  the  discretion  of  the Chairperson  of  the  Ethics
        Committee, written notification of excessive trading  may
        be  sent to you and/or the appropriate supervisor if  ten
        or  more reportable trades occur in your account(s) in  a
        month, or if circumstances otherwise warrant this action.

The following rules apply only to Access Persons:

    Exempt   List  Transactions.   Although  subject   to   prior
    clearance, transactions involving securities in certain large
    issuers  or in issuers with high trading volumes, within  the
    parameters  set by the Ethics Committee (the "Exempt  List"),
    will be approved under normal circumstances, as follows:

        Transactions  Involving  Exempt  List  Securities.   This
        exemption applies to transactions involving no more  than
        U.S.  $20,000  (all amounts are in U.S. dollars)  or  the
        nearest  round lot (even if the amount of the transaction
        marginally  exceeds $20,000) per security per  seven  (7)
        calendar day period in securities of:

                issuers with market capitalizations of $5 billion or more,
               or

                U.S. issuers with an average daily trading volume in excess
               of 500,000
               shares over the preceding 90 calendar days.

        Note  that  if the rating on the security as reported  in
        the firm's Daily Research News has been changed to a 1 or
        a  5 within the seven (7) calendar days immediately prior
        to  the  date of the proposed transaction, this exemption
        is not available.

        Transactions Involving Options on Exempt List Securities.
        Access Persons may not purchase uncovered put options  or
        sell  uncovered  call options unless otherwise  permitted
        under  the "Options and Futures" discussion on  p.  4-20.
        Otherwise,  in  the  case  of options  on  an  individual
        security  on  the  Exempt List  (if  it  has  not  had  a
        prohibited rating change), an Access Person may trade the
        greater of 5 contracts or sufficient option contracts  to
        control  $20,000  in  the underlying  security;  thus  an
        Access  Person may trade 5 contracts even if this permits
        the  Access  Person to control more than $20,000  in  the
        underlying  security.  Similarly, the Access  Person  may
        trade  more  than 5 contracts as long as  the  number  of
        contracts does not permit him or her to control more than
        $20,000 in the underlying security.  Options transactions
        on the stock of Price Group are prohibited.  See p. 4-6.

        These parameters are subject to change by the Ethics
        Committee.  An Access Person should be aware that if
        prior clearance is granted for a specific number of
        shares lower than the number requested, he or she may not
        be able to receive permission to buy or sell additional
        shares of the issuer for the next seven (7) calendar day
        under this exemption.

        Transactions  Involving  Exchange-Traded  Index  Options.
        Generally,  an Access Person may trade the greater  of  5
        contracts  or sufficient contracts to control $20,000  in
        the  underlying  securities; thus an  Access  Person  may
        trade  5 contracts even if this permits the Access Person
        to   control   more  than  $20,000  in   the   underlying
        securities.  Similarly, the Access Person may trade  more
        than  5 contracts as long as the number of contracts does
        not permit him or her to control more than $20,000 in the
        underlying  securities.  These parameters are subject  to
        change by the Ethics Committee.

        Please note that an option on a Unit Investment Trust
        (e.g., QQQ) is not an exchange-traded index option and
        does not fall under this provision.  See the discussion
        under General Information on Options and Futures below.

    Client  Limit  Orders.  The Equity Trading Desk  or  the  TRP
    International Compliance Team, as appropriate, may approve an
    Access Person's proposed trade even if a limit order has been
    entered for a client for the same security, if:

            The Access Person's trade will be entered as a market order;
          and

            The client's limit order is 10% or more away from the market
          at the time of approval of the Access Person's trade.

    Japanese New Issues.  All Access Persons are prohibited  from
    purchasing  a  security which is the subject  of  an  IPO  in
    Japan.

    Options and Futures.  Please consult the specific section  on
    Exchange-Traded Index Options above for transactions in those
    options.



     Before engaging in options and futures transactions,
     Access Persons should understand the impact that the 60-
     Day Rule and intervening client transactions may have
     upon their ability to close out a position with a profit
     (see page 4-21).


        General  Information  on  Options  and  Futures.   If   a
        transaction  in  the  underlying  instrument   does   not
        require   prior  clearance  (e.g.,  National   Government
        Obligations, Unit Investment Trusts), then an options  or
        futures  transaction  on the underlying  instrument  does
        not  require  prior clearance.  However, all options  and
        futures   transactions,  except  the  commodity   futures
        transactions  described on page  4-9,  must  be  reported
        even  if a transaction in the underlying instrument would
        not   have   to   be  reported  (e.g.,  U.S.   Government
        Obligations).   Transactions in publicly  traded  options
        on Price Group stock are not permitted.  See p. 4-6.

        Options  and Futures on Securities and Indices  Not  Held
        by  Clients of the Price Advisers.  There are no specific
        restrictions  with  respect  to  the  purchase,  sale  or
        writing  of  put or call options or any other  option  or
        futures activity, such as multiple writings, spreads  and
        straddles, on a security (and options or futures on  such
        security)  or index that is not held by any of the  Price
        Advisers' clients.

        Options  on  Securities  Held by  Clients  of  the  Price
        Advisers.  With  respect  to  options  on  securities  of
        companies  which  are  held by  any  of  Price  Advisers'
        clients,  it  is the firm's policy that an Access  Person
        should  not  profit from a price decline  of  a  security
        owned   by  a  client  (other  than  an  Index  account).
        Therefore,  an  Access  Person may:   (i)  purchase  call
        options  and sell covered call options and (ii)  purchase
        covered  put  options and sell put  options.   An  Access
        Person  may  not purchase uncovered put options  or  sell
        uncovered  call  options,  even  if  the  issuer  of  the
        underlying  securities is included on  the  Exempt  List,
        unless purchased in connection with other options on  the
        same  security  as  part  of a straddle,  combination  or
        spread  strategy which is designed to result in a  profit
        to  the Access Person if the underlying security rises in
        or  does  not  change in value.  The purchase,  sale  and
        exercise  of options are subject to the same restrictions
        as  those set forth with respect to securities, i.e., the
        option  should be treated as if it were the common  stock
        itself.

        Other  Options and Futures Held by Clients of  the  Price
        Advisers.   Any other option or futures transaction  with
        respect to domestic or foreign securities held by any  of
        the   Price   Advisers'  clients  will  be  approved   or
        disapproved   on   a   case-by-case   basis   after   due
        consideration  is  given  as  to  whether  the   proposed
        transaction or series of transactions might appear to  or
        actually create a conflict with the interests of  any  of
        the  Price Advisers' clients.  Such transactions  include
        transactions in futures and options on futures  involving
        financial instruments regulated solely by the CFTC.

        Closing  or  Exercising Option Positions.  A  transaction
        initiated by an Access Person to exercise an option or to
        close  an  option  transaction must  also  receive  prior
        clearance.  If an intervening client transaction  in  the
        underlying  security has occurred since the position  was
        opened, the Access Person may not receive prior clearance
        to  initiate a transaction to exercise the option  or  to
        close out the position, as applicable.

    Short  Sales.  Short sales by Access Persons are  subject  to
    prior clearance unless the security itself does not otherwise
    require prior clearance.  In addition, Access Persons may not
    sell  any security short which is owned by any client of  one
    of  the  Price Advisers unless a transaction in that security
    would  not  require  prior clearance.  All  short  sales  are
    subject to the 60-Day Rule described below.

   The   60-Day   Rule.   Access  Persons  are  prohibited   from
   profiting  from the purchase and sale or sale and purchase  of
   the  same (or equivalent) securities within 60 calendar  days.
   An   "equivalent"   security  means   any   option,   warrant,
   convertible  security, stock appreciation  right,  or  similar
   right  with  an exercise or conversion privilege  at  a  price
   related to the subject security, or similar securities with  a
   value  derived from the value of the subject security.   Thus,
   for  example,  the rule prohibits options transactions  on  or
   short  sales of a security within 60 days of its purchase.  In
   addition,  the rule applies regardless of the Access  Person's
   other  holdings  of  the same security or whether  the  Access
   Person  has  split  his or her holdings into  tax  lots.   For
   example,  if an Access Person buys 100 shares of XYZ stock  on
   March  1, 1998 and another 100 shares of XYZ stock on February
   28, 2002, he or she may not sell any shares of XYZ stock at  a
   profit  for  60 days following February 28, 2002.  The  60-Day
   Rule  "clock" restarts each time the Access Person  trades  in
   that security.

        Exemptions  from the 60-Day Rule.  The 60-Day  Rule  does
        not apply to:

               any transaction by a Non-Access Person except for
            transactions in Price Group stock not exempted below;

              any transaction exempt from prior clearance (e.g., exercise
            of corporate stock option by Access Person spouse, systematic
            investment plan; see p. 4-9);

               any transaction in a security in which either the
            acquisition or the sale of that  security did not require prior
            clearance (e.g., if an Access Person inherits a     security, a
            transaction that did not require prior clearance, then he or she
            may sell the security inherited at a profit within 60 calendar
            days of its acquisition);

              the purchase and sale or sale and purchase of exchange-
            traded index options;

              any transaction in Price Group stock effected through the
            ESPP (note that the 60-Day Rule does apply to shares transferred
            out of the ESPP to a securities account; generally, however, an
            employee remaining in the ESPP may not transfer shares held less
            than 60 days out of the ESPP); and

              the exercise of "company-granted" Price Group stock options
            and the subsequent sale of the derivative shares.

        Prior  clearance procedures do not check compliance  with
        the  60-Day  Rule  when considering  a  trading  request.
        Access   Persons  are  responsible  for  checking   their
        compliance with this rule before entering a trade.

        Access Persons may request a waiver from the 60-Day Rule.
        Such  requests  should  be directed  in  writing  to  the
        Chairperson  of the Ethics Committee.  These waivers  are
        not routinely granted.

    Investments  in Non-Listed Securities Firms.  Access  Persons
    may  not  purchase  or  sell the shares of  a  broker/dealer,
    underwriter or federally registered investment adviser unless
    that  entity is traded on an exchange or listed as  a  Nasdaq
    stock  or  permission  is given under the  private  placement
    procedures (see pp. 4-11; 4-14).

OWNERSHIP  REPORTING  REQUIREMENTS  -  ONE-HALF  OF  ONE  PERCENT
OWNERSHIP.   If an employee or an independent director  of  Price
Group  or  an independent director of the Price Funds  owns  more
than  1/2  of 1% of the total outstanding shares of a  public  or
private  company,  he or she must immediately report  in  writing
such  fact to Baltimore Legal/Compliance, providing the  name  of
the  company  and  the  total number  of  such  company's  shares
beneficially  owned.  The independent directors  of  the  Savings
Bank are not required to make such reports, except as they may be
specifically requested from time to time to do so by the  Savings
Bank in accordance with regulatory or examination requirements.

GAMBLING RELATED TO THE SECURITIES MARKETS.  All persons  subject
to  the  Code  are prohibited from wagering, betting or  gambling
related  to  individual securities, securities indices  or  other
similar  financial  indices  or  instruments.   This  prohibition
applies  to  wagers  placed through casinos, betting  parlors  or
internet gambling sites and is applicable regardless of where the
activity is initiated (e.g., home or firm computer or telephone).
This  specific prohibition does not restrict the purchase or sale
of securities through a securities account reporting to Baltimore
Legal/Compliance or the TRP International Compliance  Team,  even
if  these transactions are effected with a speculative investment
objective.

DISCLOSURE  OF  PERSONAL SECURITIES HOLDINGS BY  ACCESS  PERSONS.
Upon  commencement of employment, appointment  or  promotion  (no
later  than 10 days after the starting date), each Access  Person
is  required  by  United States securities laws  to  disclose  in
writing  all current securities holdings in which he  or  she  is
considered  to have beneficial ownership and control ("Securities
Holdings  Report")  (see  page 4-4 for  definition  of  the  term
Beneficial  Owner)  and  provide  or  reconfirm  the  information
regarding  all of his or her securities accounts.   The  form  to
provide  the  Securities Holding Report  will  be  provided  upon
commencement of employment, appointment or promotion  and  should
be submitted to Baltimore Legal/Compliance (U.S.-based personnel)
or   the   TRP   International  Compliance  Team   (International
personnel).  The form on which to report securities accounts  can
be found on the firm's Intranet under Corporate/Legal.

All   Access  Persons  are  also  required  to  file  a  Personal
Securities   Report,  consisting  of  a  Statement  of   Personal
Securities  Holdings and a Securities Account  Verification  Form
Report,  on an annual basis.  The reports must be as of year  end
and be filed with the firm in January of the following year.

CONFIDENTIALITY  OF RECORDS.  Price Group makes every  effort  to
protect  the  privacy of all persons and entities  in  connection
with  their  Securities Holdings Reports, Reports  of  Securities
Transactions, and Reports of Securities Accounts.

SANCTIONS.   Strict  compliance  with  the  provisions  of   this
Statement is considered a basic provision of employment or  other
association  with  Price Group and the Price Funds.   The  Ethics
Committee,  Baltimore Legal/Compliance, and the TRP International
Compliance Team are primarily responsible for administering  this
Statement.   In  fulfilling this function, the  Ethics  Committee
will  institute such procedures as it deems reasonably  necessary
to  monitor  each  person's  and entity's  compliance  with  this
Statement and to otherwise prevent and detect violations.

    Violations   by  Access  Persons,  Non-Access   Persons   and
    Directors  of  Price  Group.   Upon  discovering  a  material
    violation  of  this Statement by any person or  entity  other
    than  an  independent director of a Price  Fund,  the  Ethics
    Committee  will impose such sanctions as it deems appropriate
    and  as are approved by the Management Committee or the Board
    of  Directors including, inter alia, a letter of  censure  or
    suspension,  a  fine, a suspension of trading  privileges  or
    termination of employment and/or officership of the violator.
    In  addition,  the violator may be required to  surrender  to
    Price Group, or to the party or parties it may designate, any
    profit realized from any transaction that is in violation  of
    this  Statement.  All material violations of  this  Statement
    shall  be  reported to the Board of Directors of Price  Group
    and  to the Board of Directors of any Price Fund with respect
    to whose securities such violations may have been involved.

    Violations  by  Independent Directors of Price  Funds.   Upon
    discovering  a  material violation of this  Statement  by  an
    independent  director of a Price Fund, the  Ethics  Committee
    shall  report  such  violation to  the  Board  on  which  the
    director  serves.   The Price Fund Boards  will  impose  such
    sanctions as they deem appropriate.