Exhibit 3.17





CODE
OF ETHICS





INTRODUCTION




It is the
policy of Ministry Partners
Investment Company, LLC (together with its subsidiaries and affiliates,
the "Company") that all managers, officers and employees of the Company shall,
to the best of their knowledge and ability, adhere to, comply with and advocate
the principles set out in this code of ethics (the "Code") governing their
professional and ethical conduct in the fulfillment of their
responsibilities.




The
purposes of the Code are to:




•
            Promote
      honest and ethical conduct, including the ethical handling of actual or
      apparent conflicts of interest between personal and professional
      relationships;•
            Promote
      full, fair, accurate, timely and understandable disclosure in reports and
      documents that the Company files with, or submits to the U.S. Securities
      and Exchange Commission and in other public communications made by the
      Company;•
            Promote
      compliance with applicable governmental laws, rules and
      regulations;•
            Promote
      the prompt internal reporting of violations of the Code to appropriate
      persons of authority within the Company; and•
            Promote
      accountability for adherence to the
Code.





The Code
embodies principles to which all managers, officers and employees are expected
to adhere and advocate. Any violations of the Code may result in disciplinary
action, up to and including termination or removal, as applicable.




GENERAL
REQUIREMENTS




All
managers, officers and employees of the Company will:




1.
            Act
      with honesty and integrity, avoiding actual or apparent conflicts between
      personal and the interests of the Company, including refraining from
      receiving improper personal benefits, an inappropriate gift or kickback as
      a result of holding a particular position with the Company or which could,
      in any way, be construed as influencing or rewarding a particular course
      of action;2.
            Not
      solicit or accept, for personal or other benefit, business or similar
      opportunities that could reasonably be expected to otherwise accrue to the
      benefit of the Company;3.
            Where
      applicable, provide the U.S. Securities and Exchange Commission (the
      "Commission") and the public with complete, fair, accurate, timely and
      understandable disclosure in periodic reports and other documents filed or
      submitted to the Commission and in other public
      communications;4.
            Endeavor
      to comply with applicable laws and regulations of federal, state, local
      and foreign governments and government agencies having jurisdiction over
      the Company, and with applicable regulations of private or self-regulatory
      authorities having jurisdiction over the Company;5.
            Act
      in good faith, responsibly with due care and diligence and without
      misrepresentation or omission of material facts and strive to maintain
      independent judgment in the performance and fulfillment of their duties
      and responsibilities;6.
            Promote
      ethical behavior among subordinates and peers at the
    Company;7.
            Use
      Company assets entrusted to them in a responsible manner and refrain from
      competing directly or indirectly with the Company or using Company
      information or opportunities for personal gain;8.
            Respect
      the confidentiality of information acquired or obtained in the course of
      performance of their responsibilities, never use confidential information
      for personal advantage, and disclose confidential information of the
      Company or third parties only when such disclosure is legally required or
      is otherwise authorized.9.
            Not
      fraudulently influence, coerce, manipulate, mislead or fail to disclose
      relevant information to any auditor engaged in the performance of an audit
      for the purpose of rendering the financial statements materially
      misleading.10.
            Strive
      to retain the trust of our investors through the dissemination of full,
      fair, accurate and timely disclosure of material information required
      under applicable state and federal securities laws.11.
            Comply
      with other policies and procedures of the Company applicable to their
      positions and employment, including policies and procedures of the Company
      set forth in the Company's Employee Handbook and polices on expense
      reimbursement, travel, time cards, computer and information technology
      usage, data protection, as well as its internal financial controls and
      procedures.








FINANCIAL
INTEGRITY - ACCURACY OF BOOKS AND PUBLIC REPORTS




Employees,
officers and managers must honestly and accurately report all business
transactions and be responsible for accuracy of Company records and reports. The
Company documents a wide range of its activities. The integrity of these records
is used to make important business decisions and must be maintained at all
times. It is essential that Company records are accurate and complete. This Code
prohibits the preparation of false or misleading documentation regarding both
the amount and purpose of Company related transactions. These actions include,
for example, reports relating to financial data, costs, time sheets, payroll and
benefits records, expense reports, investor records and reports, and loan
information and records.




All
Company books, records and accounts shall be maintained in accordance with all
applicable regulations and standards and accurately reflect the true nature of
the transaction they record. The financial statements of the Company are
required to conform to generally accepted accounting policies and the Company’s
accounting policies. No undisclosed or unrecorded account or fund may be
established for any purpose.  No false or misleading entries may be
made in the Company’s books or records for any reason, and no disbursements of
Company funds or other Company property made without adequate supporting
documentation.




It is the
policy of the Company to provide full, fair, accurate, timely and understandable
disclosure in reports and documents filed with, or submitted to, the Commission
and in other public communications.  Falsification of any Company,
client or third-party record is prohibited.




There
should be no undocumented or improperly approved side agreements with vendors,
borrowers or lenders.  Any supplemental agreements to a written
contract should be referenced in the contract.




The use
of Company funds or assets for any unethical purpose is prohibited. No documents
may be altered or signed by those lacking proper authority.  No
payment on behalf of  the Company shall be made or approved with the
understanding that it will be used, or might be used, for something other than
the stated purpose.  The Company’s financial books, records and
statements shall properly document all assets and liabilities, accurately
reflect all transactions and shall be retained in accordance with the Company’s
record retention policies and all applicable laws and regulations.




Employees,
officers and managers should report any concerns regarding questionable
accounting or auditing matters to the Audit Committee Chairman.







Retention
of Business Records




Company
business records must be maintained for the periods specified by the Company’s
record retention policy. Records may be destroyed only at the expiration of the
pertinent period. In no case may documents involved in a pending or threatened
litigation, government inquiry or under subpoena or other regulatory information
request be discarded or destroyed, regardless of the period specified in the
Company’s record retention policy.  If you learn that documents or
records of any type may be required in connection with a lawsuit or government
investigation of the Company or its people, you must, by law, preserve all
potentially relevant documents. In addition, you may never destroy, alter or
conceal, with an improper purpose, any record or otherwise impede any official
proceeding, either personally, in conjunction with, or by attempting to
influence another person.




Compliance
with the Code of Ethics




All
employees, officers and managers have a responsibility to understand and follow
the Code.  A violation of this Code may result in appropriate
disciplinary action, including the possible termination of
employment.




Only the
Company's Board of Managers (the "Board") is authorized to permit a waiver of
this Code of Ethics. Any waiver of the Code for any manager or executive officer
of the Company must be disclosed on Form 8-K within five days, or such shorter
period as may be required under applicable regulation.




Reporting
Suspected Non-Compliance




It is the
duty of each manager, officer and employee of the Company to report violations
of the Code promptly to the attention of the Company's Chief Executive Officer,
President, Chief Financial Officer, Principal Accounting Officer or to any
member of the Audit Committee of the Board of Managers (the "Audit
Committee").




Every
employee, officer and manager has the responsibility to ask questions, seek
guidance, report suspected violations and express concerns regarding compliance
with this Code.  Any employee, officer or manager who knows or
believes that any other employee, officer, manager or representative of the
Company has engaged or is engaging in conduct on behalf of the Company that
violates applicable law or this Code should report such information to his or
her supervisor or to the Company’s designated compliance officer.




If you
have a concern about a questionable accounting or auditing matter and wish to
submit the concern confidentially or anonymously, please submit your concern in
writing to one of the above named officials of the Company.




You may
report such conduct openly or anonymously without fear of
“retaliation.”  The Company will not discipline, discriminate against
or retaliate against any employee who reports such conduct in good faith,
whether or not such information is ultimately proven to be correct, or who
cooperates in any investigation or inquiry regarding such conduct. The Company
will not allow retaliation against any employee that raises a concern, seeks
advice, or reports misconduct that may violate this Code. Individuals engaging
in retaliatory conduct will be subject to disciplinary action, which may include
termination of employment. If you suspect that you or someone you know has been
retaliated against for raising a compliance, ethics or integrity issue under
this Code, you should immediately contact any of the above named officials of
the Company.







Reports
of other violations of this Code may be sent (anonymously if you wish)
to  Chairman of the Audit Committee, Ministry Partners Investment
Company, LLC, 915 West Imperial Highway, Brea, Suite 120, California,
92821. Your calls, detailed notes, conversations and/or emails will be dealt
with confidentially.




The
Company will handle all inquiries discretely and make every effort to maintain,
within the limits allowed by law, the confidentiality of anyone requesting
guidance or reporting questionable behavior or other matters of concern under
the Code.




The Board
of Managers shall promptly determine, or designate appropriate persons
(including, if so determined by the Board, the Audit Committee) promptly to
determine appropriate actions to be taken in the event of violations of the Code
by any manager, officer or employee. In determining what actions are appropriate
in a particular case, the Board (or its designee) shall act consistently and
take into account relevant information including the nature and severity of the
violation, whether the violation was a single occurrence or a series of 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 manager,
officer or employee in question had committed other violations in the
past.




If the
Board or the Audit Committee believes that standards for compliance with the
Code are not objective, or that the process for determining violations is not
fair or that the Code is not conducive to prompt and consistent enforcement, or
that the protection for persons reporting questionable behavior pursuant to the
Code is inadequate (either under the Code or under the Company's other
policies), the Board shall adopt, or the Audit Committee shall recommend to the
Board for adoption, appropriate changes to the Code or other Company
policies.




It is the
Company' s intention that the Code be the Company's written Code of Ethics under
Section 406 of the Sarbanes-Oxley Act of 2002 complying with the standards set
forth in Securities and Exchange Commission Regulation S-K Item
406.