Exhibit 14.1  Coastal Carolina Bancshares, Inc. Conflict of Interest/Code of Ethics Policy  STATEMENT
OF DEFINITION AND PURPOSE  Receiving or soliciting
gifts to influence a financial transaction is strictly prohibited and may
result in stiff penalties. The Bank Bribery Act of 1984 increased the urgency
for financial institutions to educate all their employees against participation
in such transactions, by creating substantial penalties. The Bank Bribery Act
and the adoption of Regulation O of the Financial Institutions Regulatory Act
(FIRA) underscored the need for sufficient policy regarding proper
employee/customer relationships.  The Board of Directors
acknowledges the risk of conflicts of interest that may arise in obtaining
persons involved in the business and civic community to act as directors,
officers, and employees of Coastal Carolina Bancshares, Inc. (the Company)
or Coastal Carolina National Bank (the Bank). Because of such persons worth in
attracting and maintaining business relationships, the Board of Directors feels
it prudent to adopt a conflict of interest policy.  In recognizing excessive
activities and gratuities and access to information could lead to conflicts of
interest for employees, officers, and directors, the Company and the Bank have
developed this policy to recognize such positions and to prevent a loss of
objectivity by requiring appropriate and trustworthy conduct.  OBJECTIVES
AND GOALS  The general objective of
this policy is to require immediate disclosure of matters that are a potential
conflict of interest and to prevent such a situation from arising. Adherence to
this policy should prevent the development of improper relationships between
financial institution directors, officers, employees, and the customers they
serve.  The specific goals of
this policy are to:  a.Establish a monetary
limit on nominal gifts and gratuities. b.Describe situations in
which possible conflicts of interest may occur and to require proper conduct of
all employees, officers, and directors. c.Require reporting of
conflicts to superiors and written disclosures of business interests.  DEFINITIONS  For the purposes
of this policy, the following definitions apply:  Director, Officer, or
  Employee
  
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  A director, officer, or
  employee of Coastal Carolina Bancshares, Inc. or Coastal Carolina
  National Bank, or bothGift
  
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  May include cash
  or property, special discounts, price concessions, special personal items,
  special personal entertainment (other than of a normal social nature),
  special personal services, gratuitous personal services, personal favors, or
  special dispensations of any kind that could be attributed to the recipients
  position or responsibilities with the Company and/or the BankImmediate Family
  
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  Spouse, minor child,
  and/or other dependent of the director, officer, or employee  For definitions of
company, control of a company or bank, and principal shareholder and/or related
interest, refer to 12 CFR 215, Regulation O.


Coastal Carolina Bancshares, Inc. Conflict of Interest/Code of Ethics Policy  POLICY
STATEMENT  Due to the
importance placed on personal and professional ethics by management, the Board
of Directors intends to hold employees, officers, and directors to this strict
code of ethics and to require reporting of conflicts of interest. Individuals
connected to the Company and/or the Bank have primary
responsibility to uphold these standards. Failure to comply with all policies
herein described may result in the termination of employment or association.  All directors,
officers, and employees are required to act in a responsible and respectable
manner and to remain free of influences that may result in the loss of
objectivity regarding business conducted with the Banks customers or with the
Bank itself. Each such person must disclose and avoid any interests or
activities involving another organization or individual that may result in a
conflict of interest between the Company or the Bank and that organization or
individual.  While this policy
does not intend to interfere with the personal lives of directors, officers, or
employees, it requires those persons to recognize situations where conflicts of
interest may arise and to avoid them when possible. If these situations cannot
be avoided, they must be reported immediately to a direct superior.  Subsequently, the director, officer, or
employee should remove himself or herself from any compromising situations,
whether it involves advising the other person or entity or approving or voting
on extensions of credit.  CONFIDENTIAL
INFORMATION  All directors,
officers, and employees must acknowledge all information concerning bank,
customer, depositor, and director information is considered confidential and is
to be used for Bank purposes only. The use of such information for personal,
familial, or other gain is unethical and illegal under securities rulings and
the National Bank Act.  Information
regarding any business conducted cannot be disclosed to outside individuals
(unless authorized by the Bank or its customer, etc.) and may not be used for
personal gain.  Use of
confidential information other than for business purposes may result in
disclosure of insider information. Insider information is defined as
information of a material nature to affect the price of stock involved.  Insider information may not be used to
purchase, trade, or solicit securities until that information is available to
the general public.  Any transfers of
information regarding customer accounts must be strictly information that is
available to the public.  In addition, all
published information (both for internal and external use), developed programs,
equipment, etc. are the property of the Company and/or the Bank and are
reserved for use by directors, officers, or employees of the Company and the
Bank.  Use of these materials for any
other purpose may constitute copyright infringement and theft.  GIFTS
AND ENTERTAINMENT  Directors,
officers, and employees of the Company and/or Bank are not to solicit gifts
from prospective or current customers, associates, or any other individual or
business.  Any gifts received shall be of
nominal value.  Nominal value is
considered to be anything below $100. 
Employees of the Bank are expected to participate in entertainment and
amenities of reasonable cost to facilitate business.  Payment by anyone other than the Bank of
excessive costs or travel not customary or within acceptable business practice
must not be accepted.  All events,
including golf events, must be reported to your immediate supervisor prior to
participation and records maintained.  EXTERNAL
INVOLVEMENT  While the Bank
encourages its employees to be involved in outside activities, including
charitable and political functions, federal law prohibits the Bank from making
political contributions.  At no time will
employees solicit other employees for political contributions or coerce others
into contributing to any organizations. 
We will consider contributions through the Company for a donation to the
SCBA PAC. Employees are encouraged not to become actively involved in political
campaigns.  Conduct must not give the
perception that benefit the Bank or connections are sought or desired.Additionally,
offers of directorship to any outside organization that has or desires a
business relationship with the Bank, or to any institution within the financial
industry, must be approved by the CEO/President.  Capitalizing on opportunities for personal
gain or compensation outside of that provided by the Bank for the performance
of services for the Bank is strictly prohibited.


Coastal Carolina Bancshares, Inc. Conflict of Interest/Code of Ethics Policy  CONSULTATION  Refer any
questions regarding proper code of conduct to an immediate supervisor.  Actions or acceptance of gifts that are not
specifically mentioned above must be reviewed as to intent and purpose.
Directors, officers, and employees should ask themselves: If a situation were
to be made public, would my conduct be embarrassing or come into question?  CONDUCT
OF INSIDERS  12 CFR § 215, or
Federal Regulation O, defines insiders as directors, executive officers, and
principal shareholders.  These people
must take care that their conduct does not violate rules relating to
self-dealing and personal gains.  At no
time are members of this group allowed to take advantage of their position in
the Company or the Bank for personal profit or influence or credit and other
decisions with regard to their business or personal interests.  Directors and
officers are prohibited from being involved in the loan approval process of
insiders who may benefit directly or indirectly from the decision to grant
credit.  This prohibition extends to
professional relationships with any company or firm receiving remuneration as a
result of the decision to grant credit. 
Decision regarding the sale or purchase of the Companys or the Banks
assets and services must be made in the best interests of the Company or the
Bank, with no influence on insiders resulting from gifts, entertainment, or
gratuities.  All conduct of such business
must be at arms length.  LIMITATIONS
FOR CERTAIN OFFICERS, DIRECTORS, PRINCIPAL SHAREHOLDERS, AND THEIR RELATED
INTERESTS  Under Section 402
of the Sarbanes-Oxley Act of 2002, a bank holding company may not extend credit
to any of its directors or executive officers. 
However, a bank holding companys subsidiary may extend such credit
subject to the provisions of the Federal Reserve Board Regulation O.  Regulation O limits loans by the Bank to insiders,
which includes executive officers, directors, principal shareholders, and each
of their related interests.  Related
interest includes companies controlled by an executive officer, director, or
principal shareholder.  An insider also
may not knowingly permit any of his or her related interests to receive an extension
of credit in violation of Regulation O.  DISCLOSURES  Directors,
officers, and employees and officers of the Bank must make annual disclosures
of any relationships, receipt of gifts, compensation, or other situations
leading to possible conflicts in the following manner:  Employees
  
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  Report to Human
  Resource OfficerOfficers
  
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  Report to Human
  Resource OfficerExecutive officers
  
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  Report to the Human
  Resource Officer and President/CEOPresident and all
  directors
  
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  Report to Board of
  Directors  Directors,
principal shareholders, and executive officers must make annual disclosures to
the entire Board of Directors of any actual and potential conflicts of interest
and any potential conflicts of their related interests.  EMPLOYEE
ACCOUNTS  Directors,
officers, and employees are encouraged to maintain their personal accounts at
the Bank to allow the institution to provide service and direct deposit of
payroll checks.  However, under no
circumstances will the Bank pay a rate of interest in excess of the rate
available to all customers.  All
applicable fees, including overdraft charges, will be assessed on all accounts
of directors, principal shareholders, and executive officers.  At no time will overdraft fees be waived.  CONSEQUENCES
OF NONCOMPLIANCE  As previously
stated, failure to comply with this policy may result in the termination of
employment or association.  The action
taken will be commensurate with the seriousness of the conduct and an
evaluation of the situation.  All
violations of this policy will be brought to the attention of the Board of
Directors.  Termination of employment may
be determined by an officer who is the direct or indirect supervisor of the
employee concerned.


Coastal Carolina Bancshares, Inc. Conflict of Interest/Code of Ethics Policy  PROHIBITION
AGAINST KICKBACKS AND UNEARNED FEES  It is our intention to
remain in compliance with the prohibitions and restrictions contained in the
Real Estate Settlement Procedures Act (RESPA) and with Regulation X of the
Department of Housing and Urban Development. 
The Board of Directors prohibits giving or accepting any fee, kickback,
or thing of value pursuant to any agreement or understanding for the referral
of a real estate settlement service or for receiving any portion of the charge
for a settlement service other than for services actually performed.  In summary, the basic rule declares any
referral of a settlement service is not a compensable act. Compensation is
deemed to include not only direct payments (money, merchandise, or other
property), but also indirect payments such as free services or reductions in
other fees normally charged for the provision of services.