EXHIBIT 10.22


                              TOMPKINS TRUSTCO INC
                   CODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER
                          AND SENIOR FINANCIAL OFFICERS

         This Tompkins Trustco Code of Ethics for Chief Executive and Senior
Financial Officers applies to our Chief Executive Officer ("CEO") and our Chief
Financial Officer. Tompkins Trustco expects all of its employees to act in
accordance with the highest standards of personal and professional integrity in
all aspects of their activities, to comply with all applicable laws, rules and
regulations, to deter wrongdoing and abide by the Tompkins Trustco Code of
Conduct for Officers and Employees and other policies and procedures adopted by
Tompkins Trustco that govern the conduct of its officers and employees. This
Code of Ethics is intended to supplement the Tompkins Trustco Code of Conduct
for Officers and Employees.

         You agree to:

            o     Act with integrity and to engage in and promote honest and
                  ethical conduct, including the ethical handling of actual or
                  apparent conflicts of interest between personal and
                  professional relationships;

            o     Avoid conflicts of interest;

            o     Take all reasonable measures to protect the confidentiality of
                  non-public information about Tompkins Trustco or its
                  subsidiaries and their customers obtained or created in
                  connection with your activities and to prevent the
                  unauthorized disclosure of such information unless required by
                  applicable law or regulation or legal or regulatory process;

            o     To the best of your ability, provide, or cause to be provided,
                  information that is accurate, complete, objective, relevant,
                  timely and understandable to ensure full, fair, accurate,
                  timely and understandable disclosure in reports and documents
                  that Tompkins Trustco files with, or submits to, government
                  agencies, including the Securities and Exchange Commission and
                  the Federal Reserve Board, and in other public communications
                  made by Tompkins Trustco or its subsidiaries;

            o     Comply with applicable laws, rules and regulations of federal,
                  state, and local governments, and other appropriate private
                  and public regulatory agencies; and

            o     Promptly report to Tompkins Trustco's General Counsel or the
                  CEO (or any of the parties or channels listed in the Tompkins
                  Trustco Code of Conduct for Officers and Employees) and the
                  Chairman of the Audit Committee any conduct that you believe
                  to be a violation of any provision of this Code of Ethics,
                  including any material transaction or relationship that
                  reasonably could be expected to give rise to a conflict of
                  interest.

         You are prohibited from directly or indirectly taking any action to
fraudulently influence, coerce, manipulate or mislead Tompkins Trustco or its
subsidiaries' independent public auditors for the purpose of rendering the
financial statements of Tompkins Trustco or its subsidiaries misleading.

         You understand that you will be held accountable for your adherence to
this Code of Ethics. Violations of this Code of Ethics may also constitute
violations of law and may result in civil and criminal penalties for you, your
supervisor and/or Tompkins Trustco. Accordingly, the Board of Directors shall
determine, or designate appropriate persons to determine, appropriate actions to
be taken in the event of violations of the Tompkins Trustco Code of Conduct for
Officers and Employees or this Code of Ethics. Such actions shall be reasonably
designed to deter wrongdoing and to promote accountability for adherence to the
Code of Conduct and this Code of Ethics, and may include written notices to the
individual involved that the Board has determined that there has been a
violation, censure by the Board, demotion or re-assignment of the individual
involved, suspension with or without pay or benefits (as determined by the
Board) and termination of the individual's employment. In determining what
action is appropriate in a particular case, the Board of Directors or such
designee shall take into account all relevant information, including the nature
and severity of the violation, whether the violation was a single occurrence or
repeated occurrences, whether the violation appears to have been intentional or
inadvertent, whether the individual in question had been advised prior to the
violation as to the proper course of action and whether or not the individual in
question had committed other violations in the past.
<PAGE>

         It is a violation of Tompkins' Non-Retaliation Policy For Employees to
retaliate against any employee who in good faith reports any violation(s) of
this Code of Ethics.





APPROVED AT 4/25/06
BOARD MEETING