EXHIBIT 14


                           [CARVER BANCORP INC. LOGO]


                                       and



                       [CARVER FEDERAL SAVINGS BANK LOGO]


                                 Code of Ethics




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Table of Contents

Table of Contents.....................................................2

CODE OF ETHICS........................................................3
   Foreword...........................................................3
   The Code of Ethics.................................................4
     Confidentiality..................................................4
     Self-Interest....................................................4
     Lending..........................................................6
     Holding Office/Appointments......................................7
     Internal Accounting Controls.....................................8
     Internet and Email Usage.........................................8
     Trading in Company Stock.........................................9
     Trading in the Stock of Bank Customers, Suppliers, or Vendors....9
     Compliance......................................................10
     Supervision.....................................................10
     Administration..................................................10

   CODE OF ETHICS ACKNOWLEDGMENT

   FREQUENTLY ASKED CODE OF ETHICS QUESTIONS


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CODE OF ETHICS

     To achieve its potential as a top-tier financial  services company,  Carver
     Bancorp,  Inc.  (the  "Company"),  Carver  Federal  Savings  Bank  ("Carver
     Federal") and all associated  affiliates  (collectively  referred to as the
     "Bank")  must  attract  and  retain  quality  employees  dedicated  to  the
     performance of their duties in a highly ethical and moral fashion.

Foreword

     The Bank has established  this Code of Ethics to protect the reputation and
     integrity of the Bank and its  directors,  officers and  employees,  and to
     assist its directors, officers and employees in following uniform standards
     of ethical conduct.

     The  Code  of  Ethics  is  intended  to  govern  the  actions  and  working
     relationships  of Bank  directors,  officers and employees  with current or
     potential customers, consumers, fellow employees,  competitors,  suppliers,
     government  representatives,  the media, and anyone else with whom the Bank
     has contact. In these relationships, directors, officers and employees must
     observe the highest  standards of ethical conduct.  The success of the Bank
     as a provider  of banking  and other  financial  services is built upon the
     trust and confidential  relationships  maintained  between the Bank and its
     customers;  therefore,  each director,  officer and employee is expected in
     all  business  matters  to place the Bank's  interest  above his or her own
     self-interest.

     This Code of Ethics  reaffirms  and  clarifies the Bank's basic policy that
     conflicts of interest,  or the  appearance  of conflicts of interest,  must
     always be resolved  in keeping  with the  policies  of the Bank.  It is the
     Bank's policy that a director,  officer or employee maintain no position or
     interest,  financial  or  otherwise,  which  (1)  could  conflict  with the
     performance of their duties and  responsibilities  to the Bank, (2) affects
     or could  affect their  independence  or judgment  concerning  transactions
     between the Bank and its customers, suppliers, or others with whom the Bank
     competes or has existing or pending or potential business relationships, or
     (3)  otherwise  reflects  negatively  on the  Bank  (each  a  "Conflict  of
     Interest").

     Employees must resolve any doubt as to the meaning of the Code of Ethics in
     favor of good,  ethical judgment.  It is each employee's  responsibility to
     avoid even an appearance of impropriety.

     Implicit  in the Code of Ethics is the  Bank's  policy  that the Bank,  its
     directors,  and its  employees  comply with the law.  The law  prescribes a
     minimum  standard of conduct;  the Code of Ethics  prescribes  conduct that
     often  exceeds the legal  standard.  Any request made of an employee by any
     supervisor carries with it, whether or not articulated, the caveat that the
     employee is to comply with the request  only to the extent he or she can do
     so while complying both with the law and this Code of Ethics.

     This Code of Ethics  supersedes and replaces all previously  published Bank
     Code of Ethics, including that adopted during March 2004.


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The Code of Ethics

     The following principles apply to all directors,  officers and employees of
     the Bank:

     CONFIDENTIALITY

     Nonpublic  information  regarding  the Bank or its  businesses,  directors,
     officers,  employees,  customers,  suppliers,  or consumers is confidential
     ("Confidential  Information"),  and,  except for job duties at the Bank and
     where  permissible  under the Bank's  Privacy  Policy or  required  by law,
     employees  may neither  disclose  Confidential  Information  nor use it for
     trading  in  securities  or  for  other   personal  gain  during  or  after
     employment.

     Confidential  Information  should be  guarded to ensure  that  unauthorized
     personnel, including customers and other employees of the Bank, cannot gain
     access.  Appropriate methods of guarding  Confidential  Information include
     holding  verbal  conversations  away from  unauthorized  personnel  and the
     locking away of  documentation  containing  Confidential  Information.  Any
     sharing of  Confidential  Information  either  verbally or in writing could
     result in lawsuits or regulatory  sanctions  against the  institution,  its
     employees  and customers and could  severely  damage the  reputation of the
     Bank.

     Public communication  involving the Bank must have prior clearance from the
     President or the President's designee.

     SELF-INTEREST

     Directors, officers and employees are prohibited from:

        1.    Accepting employment or engaging in a business (including
              consulting  and  similar   arrangements   or   arrangements   with
              competitors)  that  may  conflict  with the  performance  of their
              duties or the Bank's interest.

        2.    Hiring relatives if the employee will have direct
              supervisory responsibility or control over compensation decisions.

        3.    Soliciting or demanding, or accepting or agreeing to accept
              (except as provided  below),  anything of value from any person in
              conjunction with the performance of their duties at the Bank.

        4.    Accepting personal fees, commissions, other compensation paid, or
              expenses paid or reimbursed  from others,  not in the usual course
              of the  Bank's  business,  in  connection  with  any  business  or
              transaction involving the Bank.

        5.    Acting on behalf of the Bank in any transaction involving others
              with whom they or their  immediate  families have any  significant
              direct or indirect financial interest.

        6.    Borrowing money from customers or suppliers unless the customer or
              supplier is a financial  institution  that makes such loans in the
              ordinary course of its business.

        7.    Purchasing property, whether real, personal, or intangible, from
              the Bank  without the  approval of the Board of  Directors  or the
              Board's  designee  unless  the  Bank  makes  a  general  offer  of
              extraneous property to employees on a non-discriminatory basis.

        8.    Purchasing property obtained by the Bank through repossession or
              foreclosure,  including the sale of such property to any member of
              an individual's family.

        9.    Making any political contribution of money or other property on
              behalf of the Bank that would violate federal or state law.

        10.   Engaging in excessive speculation, borrowing, or gambling.

        11.   Permitting Bank property (including data transmitted or stored
              electronically,  products and services  developed by the Bank, and
              computer   resources)   to  be  damaged,   lost,  or  used  in  an
              unauthorized manner.

        12.   Providing Bank customers with legal, tax or investment advice or
              recommending attorneys, accountants, securities dealers, insurance
              agents, brokers, real estate agents, or other service providers if
              the recommending  employee receives a personal  reciprocal benefit
              for the referral from the service provider.

        13.   Engaging or investing in any business that directly or indirectly
              competes with services  provided by the Bank or any  subsidiary of
              the Bank, except where such an investment represents insignificant
              ownership  in  a  publicly  traded  company.  The  making  of  any
              investment is subject to Section A of this Code of Ethics.

        14.   Using Confidential Information for personal benefit or disclosing
              such information to others outside of job duties.

        15.   Misusing the Bank's electronic message  communications system.

        16.   Doing any of the above actions indirectly through another person.

A director,  officer or  employee  may accept  normal  business  amenities  that
facilitate the discussion of business,  foster good business relations, or serve
some other demonstrable business purpose. Gifts of nominal value may be accepted
from  present  or  prospective  customers,  suppliers,  or  vendors  with whom a
director,  officer,  or  employee  maintains  an  actual or  potential  business
relationship,  but generally must not exceed,  in the  aggregate,  $200 in value
from any one  individual/entity  in any one  calendar  year  unless  approval is
obtained from the employee's immediate  supervisor,  in the case of an employee,
or from  the  Chairman  of the  Finance  and  Audit  Committee  of the  Board of
Directors, in the case of a director, and the Code of Ethics Officer.  Discounts
and price  reductions not generally  available to others are  considered  gifts.
Directors,  officers and  employees  may not accept cash gifts in any amount and
must  report any such  attempted  gift to the  Chairman of the Finance and Audit
Committee or their immediate supervisor as the case may be. Further,  directors,
officers and employees are expressly  prohibited from  soliciting,  demanding or
accepting  anything  of value with the intent to be  influenced  or  rewarded in
connection with any business transaction or relationship involving the Bank. The
term "gift" does not include any discounts or programs that are available to all
employees  under a general  offer that has been  approved  by the  Bank's  Human
Resource Department.

Reasonable  entertainment  may be engaged in between an employee  and present or
prospective  customers,  suppliers  or  vendors.  However,  the  value  of  such
entertainment  may not exceed,  in the aggregate,  $200 per calendar year unless
the  customer,  supplier,  or vendor is  present.  For  purposes of this Code of
Ethics, "reasonable entertainment" means entertainment,  the purpose of which is
to hold bona fide business discussions,  and for which the expense would be paid
by the Bank as a  reasonable  business  expense if the Bank had paid the expense
itself.

If  there  is  any  question  about  the  propriety  or  reasonableness  of  any
entertainment,  such as when the host will not be present,  the employee  should
secure the  approval  of the  employee's  immediate  supervisor  and the Code of
Ethics Officer.  Approval by the employee's immediate supervisor and the Code of
Ethics Officer is also required for any entertainment in excess of $200 in value
if the customer,  supplier or vendor is not present or for any gift in excess of
$200 in value. Prior approval is required for all out-of-town  sporting or other
social events even if the customer, vendor, or supplier will be present, and the
employee may accept only the ticket to the event and any meals and entertainment
served or provided in conjunction  with the event. In the event that an employee
is offered or receives something of value beyond what is authorized in this Code
of Ethics,  the employee must promptly  disclose such fact to the Code of Ethics
Officer.

An employee must report to the Code of Ethics  Officer any potential  bequest in
excess of $200 to the employee under the will or trust instrument of a customer,
vendor or supplier of the Bank,  whether or not the Bank is the fiduciary  named
under such instrument,  unless the customer,  vendor, or supplier is a member of
the employee's immediate family.  Bequests in excess of $200 shall be subject to
the written  approval of the  employee's  immediate  supervisor  and the Code of
Ethics Officer.

In certain  circumstances,  Bank  employees  are  prohibited  from  accessing or
viewing  personal  information  of Bank  customers  or  consumers,  from sharing
non-public information about Bank customers or consumers with unaffiliated third
parties,  and from  marketing to Bank customers or  prospective  customers.  For
specific information about customer privacy requirements, see the Bank's Privacy
Policy.

All directors, officers and employees are expected to demonstrate the ability to
properly manage their personal finances, particularly the prudent use of credit.
Directors, officers and employees should remain aware that the improper handling
of personal finances could undermine their personal as well as the institution's
credibility  and  that a  precarious  financial  position  could be  thought  to
influence actions or judgments made for the institution.  Directors, officers or
employees who encounter  personal  financial  problems are  encouraged to obtain
counseling.  Managers who are aware of individuals having difficulty in managing
personal  finances  should report this  information  immediately  to the Code of
Ethics Officer. All directors, officers and employees should refer to the Bank's
Human Resources policies for additional guidance.

LENDING

All  directors,  officers,  and  employees of the Company and its  subsidiaries,
including  Carver Federal,  are subject to the provisions of Regulation O of the
Federal  Reserve Board of Governors with regard to all extensions of credit from
the Company's subsidiaries.

As  a  matter  of  policy,   the  Bank  avoids   making  loans  where   personal
considerations  may affect either the exercise of prudent credit judgment or our
ability to employ normal collection techniques. As an example, caution should be
exercised  in  making  loans to  close  relatives  of  directors,  officers  and
employees  since  such loans can  become  embarrassing  to handle in view of the
personal relationships.  Also, we must scrupulously avoid a situation in which a
loan might be made to a borrower for the purpose of financing the purchase of an
automobile  or other asset from a director,  officer or employee of the Bank.  A
loan officer entirely removed from any ownership or other personal  interest may
make  these  loans  only  under  genuine  "arms-length"  conditions.   Under  no
circumstances may a loan officer make a loan to his or her relatives or business
associates.  Loan  applications  from close friends should normally be passed to
another officer of the Bank for processing.

The Bank adheres  strictly to the  provisions of Section 563.43 of the Office of
Thrift Supervision  Regulations (the "OTS Regulations") covering restrictions on
loans and other investments involving "affiliated persons".

Loans to directors as well as loans to any direct relation (i.e., child, spouse,
etc.) of a director must have prior Board of Directors approval.  Board approval
requires  a majority  affirmative  vote of the Board  with the  affected  member
abstaining from  discussion and voting.  Such approvals will be made a matter of
record in the minutes of the meeting.

Unless  otherwise  permitted by a  resolution  adopted by the Board of Directors
with respect to certain  loans to directors,  officers or employees,  the rates,
terms,  and  conditions  must be similar to those  offered to  borrowers in like
circumstances  but  without  an  affiliation   status.  The  terms,  rates,  and
conditions  must be consistent  with those being  charged  borrowers who have no
direct  connection with the Bank,  unless  otherwise  permitted  pursuant to the
resolution  adopted by the Board of Directors.  Underwriting  and  documentation
standards shall be the same as for any other customer.  For specific information
about loans to directors, officers and employees, see the Bank's Lending Policy.

The Bank shall adhere to Section 563.93 of the OTS Regulations as to total loans
to one  borrower.  The ability to repay all the loans in the  aggregate  must be
considered. The Bank will place a strict interpretation on the intent of the OTS
Regulations  pertaining  to  "common  sources  of  repayment".  No loan shall be
granted when the ability to meet the required payments are not clearly evident.


HOLDING OFFICE/APPOINTMENTS

The written approval of the Board of Directors, or the Board's designee(s),  and
the Code of Ethics Officer, is needed before an officer or employee may become a
director,  officer,  or partner of any business  organized  for profit.  If such
service is on behalf of the Bank, the director,  officer,  or employee must turn
over  all  compensation  received  for  such  service  to the  Bank  other  than
reimbursement of out-of-pocket expenses.

Directors,   officers,   and  employees  are   encouraged  to   participate   in
organizations  that  are  involved  in  charitable,  educational,  or  community
activities, and no approval is needed for involvement with such organizations.

Directors,  officers,  and employees are  encouraged to participate in civic and
political  activities.  A director,  officer,  or employee  may hold a part-time
elective  or  appointive  office  and may  participate  in  political  campaigns
provided  written approval of the Board of Directors,  or the Board's  designee,
and the Code of Ethics Officer is obtained. Full disclosure of the time involved
and the  compensation  to be  received  must be  included  with the  request for
approval.  In most cases  when a  director,  officer,  or  employee  seeks or is
appointed  to a  political  office,  he or she must  obtain an opinion  from the
political  entity's  legal counsel  stating that the candidacy is not prohibited
and that the  election or  appointment  will not bar the  political  entity from
doing business with the Bank.

Employees must avoid appointments,  including fiduciary appointments,  which may
conflict  with  the  performance  of  their  duties  for the  Bank or  otherwise
interfere  with their  employment  relationship  with the Bank.  The  employee's
supervisor  and the Code of Ethics  Officer must approve all fiduciary and other
appointments, except those on behalf of the employee's immediate family members,
prior to the employee's acceptance of the appointment.

If, prior to the next  certification  period,  the  employee's  responsibilities
within the Bank change,  the employee must repeat any required approval process,
even though the employee's former manager approved the position/appointment.


INTERNAL ACCOUNTING AND DISCLOSURE CONTROLS

It is the legal  responsibility  of the Bank to develop and maintain  systems of
internal  accounting and disclosure  controls that permit the preparation of its
financial  statements and disclosures in accordance with applicable laws, rules,
and accounting  principles,  including the full,  fair,  accurate,  timely,  and
understandable  disclosure in the periodic  reports  required to be filed by the
Bank.

No one shall, directly or indirectly, knowingly falsify or cause to be falsified
any book,  record or  account  of the Bank or  knowingly  disclose  any false or
misleading information about the Bank. This includes expense accounts,  approval
of  invoices  submitted  by vendors,  records of  transactions  with  customers,
records  of  disposition  of  Company  assets,  records  of  consumers,  records
submitted in accordance with the Company's Expense  Reimbursement Policy, or any
other record regardless of whether it is financial in nature.

Any director, officer, or employee who becomes aware, directly or indirectly, of
inadequate  accounting  or  disclosure  controls,  a failure of  controls,  or a
circumvention  of  controls,  that  transactions  or other items are  improperly
recorded on the Bank's books or records,  or that disclosures made or to be made
by the Company are false or misleading must promptly report the situation to the
Bank's Chief Auditor or the Code of Ethics Officer.

INTERNET AND EMAIL USAGE

All users  (employees,  consultants,  contract  workers  or other  Bank  agents)
("Persons") are personally  responsible for ensuring that the Bank's  technology
is used for business purposes.  Email and access to the Internet is NOT intended
for use for personal reasons, to promote the interest of any particular employee
organization  or group,  or for  illegal  or  unethical  activities  that  would
jeopardize the legitimate interest of the Bank.

The term Occasional  Personal Use is used throughout the policies and procedures
of the  Bank.  It  shall  be  applied  only in the  context  of  using  Personal
Productivity  Tools,  Electronic   Communication  Tools  and  office  automation
technology.  Personal  Productivity  Tools and Electronic  Communications  Tools
include (but are not limited to) the Microsoft Office Suite,  telephone  access,
Internet access,  e-mail, and office automation  technology (e.g. copy machines,
calculators).  Furthermore,  specific  guidelines and  restrictions  are defined
within the specific  standards  for the usage of the Bank's  e-mail and Internet
capabilities.  Banking  Applications  and services (as defined in Section IV. D.
Banking  Applications  Control  of the  Bank's  Information  Security  End  User
Standards) are prohibited from Occasional  Personal Use under all  circumstances
by all Persons.  Occasional  Personal Use is permitted  during  non-working time
periods,  provided that such use otherwise  conforms to the permissible uses and
limitations  set forth in the  Bank's  policies  and this Code of  Ethics.  Such
Occasional  Personal  Use must not hinder or  interfere  in any manner  with the
performance of the duties and other  responsibilities  of any Person's  position
and duties  performed for the Bank. This is a privilege and Persons are expected
to exercise appropriate discretion and judgment when using the Bank's technology
for  Occasional  Personal  Use.  Occasional  Personal Use will be monitored  and
appropriate  disciplinary  actions  will be  administered  for  abuse  of  these
privileges.


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Examples of use that is  prohibited  would  include,  but not be limited to, the
following:

        1.    Communicating material for personal gain or use (e.g., apartment
              rental,  sales of  goods  and  services,  outside  employment,  or
              nonbank related business activities, etc.)

        2.    Viewing, exchanging, or initiating pornography, slurs, epithets or
              other  material that is  disparaging  or offensive  based on race,
              color, national origin, sex, sexual orientation,  age, disability,
              religious or political beliefs,  or any individual's status in any
              protected group or class.

        3.    Attempting to download, copy store or transmit material that may
              violate  copyright  or  licensee  restrictions  or  is  offensive,
              defamatory, obscene or discriminatory.

        4.    Degrading, criticizing or impugning the motives or ethics of other
              companies, individuals, or groups, including our competitors.

        5.    Disseminating information regarding matters of concern to employee
              organizations or unions (bulletin boards for posting bulletins and
              notices  and  materials  issued  by  employee   organizations  are
              provided for this purpose).

        6.    Engaging in any activity of a political nature (e.g. to campaign,
              solicit signatures on petitions,  solicit political contributions,
              etc.)

TRADING IN COMPANY STOCK

No one shall buy,  sell,  donate,  or  otherwise  participate  in a  transaction
involving  Company  stock while in  possession  of  information  concerning  the
Company  which has not been  released  to the  general  public  but  which  when
released may have an impact on the market price of Company stock.  Directors and
officers are  prohibited  from  transacting  in Company stock except during safe
harbor periods as defined by the Securities and Exchange Commission ("SEC"). Any
transactions  during the safe harbor must be  communicated to the Bank's General
Counsel for possible  disclosure of insider trading activities with the SEC. For
further information regarding transactions in Company stock, directors, officers
and other  employees are  encouraged  to review the Statement of Company  Policy
Regarding   Confidential   Information  and  Stock  and  Securities  Trading  by
Directors,  Officers  and  Employees.  Questions  concerning  the  propriety  of
participating  in a Company stock  transaction  should be directed to the Bank's
General Counsel.

TRADING IN THE STOCK OF BANK CUSTOMERS, SUPPLIERS, OR VENDORS

Customer  Securities.  No employee may knowingly  invest in the  securities of a
customer of the Bank if (a) the employee (i)  participates  in, (ii) is expected
to  participate  in, or (iii) is  responsible  for,  extensions of credit to the
customer or (b) the customer's  securities are publicly  traded and the employee
has nonpublic  information  concerning  the customer at the time of the proposed
investment.  In no case may the  employee  invest in the  customer's  securities
until  after  making  disclosure  of the  proposed  investment  to the  Board of
Directors, to the person approving the transaction with the customer, and to the
Code of Ethics Officer.

Supplier  or  Vendor  Securities.  No  employee  may  knowingly  invest  in  the
securities of a supplier or vendor if (a) the employee (i) participates in, (ii)
is expected to participate in, or (iii) is responsible for, decisions  involving
business  transactions  with the supplier or vendor,  or (b) the  securities are
publicly traded and the employee has nonpublic information about the supplier or
vendor at the time of the  proposed  investment.  If an employee has an existing
investment  in the  securities  of a  supplier  or  vendor  of the Bank and such
employee  participates  or is expected to participate  in or is responsible  for
decisions  involving  business  transactions  with the vendor or  supplier,  the
employee  shall  promptly  disclose  the  investment  to his  or  her  immediate
supervisor  and the Code of  Ethics  Officer  and  shall  refrain  from  further
participation in such decisions unless expressly authorized in writing by his or
her immediate supervisor and the Code of Ethics Officer. An employee may make an
insubstantial  investment  in the publicly  traded  securities  of a supplier or
vendor even though such employee  participates  or is expected to participate in
or is responsible for decisions involving the supplier or vendor if the employee
obtains the prior approval of the employee's  immediate  supervisor and the Code
of Ethics Officer.

COMPLIANCE

Each  director,  officer and employee of the Bank shall act on the Bank's behalf
in a manner that  complies  with all laws and  regulations  under which the Bank
must  operate.  (As an  example,  the Bank is  required  to  report  large  cash
transactions and certain types of monetary  instruments as a means of preventing
crimes  such as money  laundering  and tax  evasion.  See the Bank's  policy and
procedure on the Bank  Secrecy  Act.) Any  employee  who becomes  aware,  either
directly or  indirectly,  of a Bank  employee's  violation of a law  involving a
breach of trust must report the violation promptly to the Bank's Chief Auditor.

If a director,  officer or employee  becomes aware of or suspects  embezzlement,
false entries in the Bank's records,  false statements to the Bank's regulators,
false  statements  by  customers or consumers  (where the  director,  officer or
employee  knows that the  statement  is false or has reason to inquire as to its
falseness),  or any  fraud  or  potential  fraud,  or other  criminal  violation
involving  the Bank,  its  employees or  customers,  such  director,  officer or
employee must immediately contact the Bank's Security Officer or Chief Auditor.

A director,  officer or employee who is convicted of a crime,  including a crime
involving a breach of trust or a crime  classified  as a felony,  or who becomes
subject to a  suspension  or removal  order by a bank  regulatory  agency,  must
report  the  event to the  employee's  immediate  supervisor,  in the case of an
employee or officer,  or the Chairman of the Finance and Audit  Committee of the
Board of Directors, in the case of a director, and the Code of Ethics Officer.

SUPERVISION

It is the responsibility of each supervisor to train and supervise  employees so
that they are able to perform their job in a competent  manner and in conformity
with  the  Bank's  policies,  including  this  Code of  Ethics.  When  assigning
responsibilities to an employee, it is the supervisor's responsibility to ensure
that the employee has  demonstrated  the  capability  to discharge  the assigned
responsibility  in  conformity  with  this  Code  of  Ethics.  It  is  also  the
supervisor's responsibility to ensure that all employee questions concerning the
operation  and  requirements  of this Code of Ethics  are  fully  addressed  and
understood by each employee.  Whenever an employee violates this Code of Ethics,
the adequacy of such employee's training and supervision will be reviewed.

ADMINISTRATION

        1.    The Bank shall appoint a Code of Ethics Officer who will be
              responsible  for  the  administration  of  this  Code  of  Ethics.
              Questions  on  this  Code  of  Ethics  should  be  referred  to an
              employee's supervisor or the Code of Ethics Officer. With approval
              of this policy,  the Chief Auditor is hereby appointed the Code of
              Ethics Officer.



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        2.    Whenever this Code of Ethics requires disclosure or approval,
              directors,  officers or employees  shall  promptly  make a written
              report with a full account of the circumstances to the Finance and
              Audit Committee of the Board of Directors or their supervisor,  as
              applicable, and the Code of Ethics Officer.

        3.    The Code of Ethics Officer will document the resolution of any
              known Code of Ethics  violations or any outside economic  interest
              of directors,  officers,  and employees and notify the Finance and
              Audit Committee of the Board of Directors (who will in turn notify
              the Board of Directors) at the next scheduled meeting.

        4.    Anyone wishing to communicate known or suspected violations of
              the Code of  Ethics  directly  to the  Bank's  Finance  and  Audit
              Committee of the Board of Directors  may do so by  contacting  the
              Bank's Compliance Line at 1-800-399-2305 or by forwarding  written
              correspondence,  marked  "CONFIDENTIAL,"  to  the  address  below.
              Contact may be made  anonymously  and will remain  confidential to
              the extent possible to fully investigate allegations:

                           Chairman of the Finance and Audit Committee
                           C/O Carver Bancorp, Inc.
                           75 W. 125th St., 4TH Floor
                           New York, NY 10027

        5.    New directors, officers and employees shall either receive a
              printed  copy or be  directed to review an  electronic  version of
              this Code of Ethics as a part of their orientation.

        6.    All supervisors are responsible for reviewing this Code of
              Ethics with their subordinates each time a new edition of the Code
              of Ethics is published.

        7.    All directors, officers and employees must promptly complete
              and return an annual  acknowledgement  of receipt  and  compliance
              with this Code of Ethics.

        8.    All directors, officers, and employees must disclose in the
              annual  acknowledgement,  loans and other  financial  transactions
              with the Bank. In addition, not less than annually,  directors and
              executive  officers must submit an accurate Directors and Officers
              Questionnaire  for  inclusion  in  the  SEC  Form  10K,  including
              disclosure of outside economic interests.

        9.    Each director, officer and employee is responsible for reporting
              to the Code of Ethics  Officer any  activity  that may violate the
              Code of  Ethics,  whether  the  activity  involves  the  director,
              officer or  employee  or another  director,  officer or  employee.
              Reporting  the  activity  will  not  subject  the   individual  to
              discipline absent a knowingly false report.

        10.   The Code of Ethics is part of the Bank's personnel policies so
              that  employees  who violate the Code of Ethics are subject to the
              disciplinary  measures  set  forth  in  those  policies  up to and
              including termination.

        11.   The Code of Ethics Officer shall provide a quarterly report to
              the OTS Regional  Director,  describing all matters  arising under
              the Code of Ethics during the quarter and the resolution thereof.

        12.   The Bank prohibits retaliation against any individual who
              reports an actual or suspected  violation of the Code of Ethics or
              participates  in an  investigation  of such  violation.  Reporting
              actual or suspected  violations will not subject the individual to
              discipline absent a knowingly false report. Retaliation against an
              individual  for reporting  violations or for  participating  in an
              investigation  of a violation is a serious  violation of this Code
              of Ethics  and,  like a Code of Ethics  violation  itself,  may be
              subject to disciplinary action, up to and including termination.

The Bank, acting by and through its Board of Directors,  shall have the sole and
absolute  discretionary  authority to administer  and approve any deviation from
this Code of  Ethics.  The Board of  Directors  shall  appoint a  non-management
member  of the  Board  to be  responsible  for  maintaining  or  overseeing  the
maintenance  of all  records,  including  the  receipt and  retention  of annual
acknowledgements  and confidential  correspondence  regarding violations of this
Code of Ethics regarding the matters governed by this Code of Ethics.

Employees  should  feel free to contact  the Code of Ethics  Officer for related
communications  on this Code of Ethics or to seek guidance on the  procedures to
be followed with regard to reporting items under this Code of Ethics.

Each of the Carver  Bancorp,  Inc.  and  Carver  Federal  Savings  Bank Board of
Directors adopts this Code of Ethics via resolution as of February 22, 2005.



Re-approved: February 07, 2006


<PAGE>


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<PAGE>



EXHIBIT A

                             CARVER BANCORP, INC. &
                           CARVER FEDERAL SAVINGS BANK



CODE OF ETHICS ACKNOWLEDGMENT


I hereby  acknowledge  that I have  received  a copy of the Code of Ethics  (the
"Code") of Carver Bancorp,  Inc., Carver Federal Savings Bank and all associated
affiliates  (collectively,  "Bank")  updated  February 22, 2005; and that I have
read  and  understand  the  Code  and  will  abide  by the  provisions  thereof.
Additionally,  I have  checked  the box  below  and  provided  information  that
appropriately reflects my current compliance with the Code:

_______  I am not in  violation  of the  Bank's  Code nor am I aware of any such
activities.

_______ I am  required  to  disclose  activities  related to the Bank's  Code as
follows:

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Signature: ___________________________________

Name: ______________________________________

Title/Position: ________________________________

Date: ________________




____ Initial Acknowledgment

____ Annual Acknowledgment



<PAGE>


       FREQUENTLY ASKED CODE OF ETHICS QUESTIONS
         WHAT IS THE BANK CODE OF ETHICS?

              The  Code  of  Ethics  (the  "Code")  is a  compilation  of  basic
              principles  of conduct  for which  you,  as a Bank  employee,  are
              responsible.  These principles are the basic values upon which the
              Bank's  customers  and  others who deal with the Bank have come to
              rely:  integrity and honesty in the Bank's  provision of financial
              services.



              As a Bank  employee,  it is  your  responsibility  to  familiarize
              yourself  with  the  Code's   requirements  and  to  follow  those
              requirements.  This  question/answer  section is only a summary of
              the Code's  provisions.  Make  certain to read the entire Code and
              understand its provisions.  Very simply,  however,  you must avoid
              the following:


SELF-INTEREST.

     o    Engaging  in  outside   employment,   which  may  conflict   with  the
          performance of your duties or the Bank's interests.

     o    Soliciting  or  accepting  anything  of other  than  nominal  value in
          connection with the performance of your duties.

     o    Purchasing property from the Bank through  repossession or foreclosure
          or without proper approval either directly or indirectly.

     o    Engaging in excessive speculation, borrowing, or gambling.

     o    Investing  in the  securities  of a current or  prospective  customer,
          supplier,  or vendor of the Bank if the securities are publicly traded
          and  you  have  nonpublic   information   about  the  entity,  if  you
          participate  in  credit  decisions   involving  a  customer,   if  you
          participate in business  decisions  involving a supplier or vendor, or
          unless you make prior disclosure of your investment in a customer with
          which you have a non-credit business relationship.

     o    Buying or selling  Carver  Bancorp,  Inc.  stock based upon  nonpublic
          information.



GIFTS

     o    You may not  accept  cash  gifts in any  amount and you may not accept
          other gifts or  entertainment,  which exceed in the aggregate  $200 in
          value from any one  individual/entity in any one calendar year without
          approval  from  your  immediate  supervisor  and the  Code  of  Ethics
          Officer.



HOLDING OFFICE/APPOINTMENTS

     o    Without prior  approval,  you may not become a director,  officer,  or
          partner of any business organized for profit.

     o    You are  encouraged to participate  in  charitable,  educational,  and
          community activities.

     o    You must obtain the Bank's  authorization  prior to holding a civic or
          political  elective  or  appointive  office,  or  participating  in  a
          political fund-raising campaign.


     Under the  Bank's  Code of Ethics you are  responsible  for  reporting  any
     activity,  which may be in  violation of the Code,  whether  that  activity
     involves you or another the Bank employee. See also Question 21.


IF I HAVE A CODE QUESTION, WITH WHOM DO I SPEAK?

Initially contact your immediate  supervisor.  If you desire to speak to someone
other than your  supervisor,  contact the Bank's Code of Ethics Officer at (212)
360-8844.

I HAVE BECOME AWARE OF A SITUATION INVOLVING SEVERAL CO-EMPLOYEES THAT I BELIEVE
VIOLATES THE CODE,  BUT I AM NOT CERTAIN.  I DO NOT FEEL  COMFORTABLE  REPORTING
THIS SITUATION TO MY CODE OF ETHICS  OFFICER OR THE BANK'S AUDITOR  BECAUSE I AM
NOT CERTAIN I KNOW ALL THE CIRCUMSTANCES INVOLVED IN THE SITUATION, AND I DO NOT
WANT TO "CAUSE TROUBLE." WHAT SHOULD I DO?

The Bank has several  options for  communicating  "possible"  Code violations as
follows:

The Carver  Compliance  Line was  established to provide you with a confidential
mechanism to talk with an ethics professional regarding possible violations. All
calls will be kept anonymous to the extent that you desire your  confidentiality
to be  maintained.  Posters  have been  placed  in all  Company  locations  with
information   on  the   Compliance   Line   including  the  contact   number  of
1-800-399-2305.

A  suggestion  box located in the break room on C level of the Main  Office.  To
report a "possible" Code violation without  necessarily  revealing your identity
or the identity of the parties  involved,  you can document  your  knowledge and
seal the  document in an  envelope  addressed  to the "Code of Ethics  Officer".
Human  Resource  personnel  responsible  for accessing the  suggestion  box will
deliver  any sealed  envelopes  to the Code of Ethics  Officer  immediately  for
review/follow-up.

Alternatively,  you may forward correspondence marked "CONFIDENTIAL" directly to
the Bank's Finance and Audit Committee at:

        Chairman of the Finance and Audit Committee
        C/O Carver Bancorp, Inc.
        75 W. 125th St.
        New York, NY  10027

I READ IN THE CODE THAT IF I AM CONVICTED OF A CRIME, I MUST REPORT THIS FACT TO
THE CODE OF ETHICS  OFFICER.  WHAT  CRIMES  ARE  INCLUDED?  WHAT  ABOUT  TRAFFIC
VIOLATIONS?

While there is no absolute  definition of what  constitutes a reportable  crime,
those offenses  involving a breach of trust,  such as embezzlement,  passing bad
checks, theft, fraud, shoplifting,  robbery,  misrepresentation,  and falsifying
records,  or any offense  classified as a felony offense must be reported to the
Code of Ethics  Officer.  Minor traffic  violations  such as parking or speeding
tickets  when no one was injured  need not be  reported.  If you are not certain
whether a criminal  conviction  involved  or  constituted  breach of trust,  you
should review the matter with the Code of Ethics Officer.

MAY I SERVE AS A DIRECTOR, OFFICER, OR PARTNER OF A FOR-PROFIT ENTITY? DO I NEED
TO OBTAIN ANY SPECIFIC APPROVAL?

Under the Code, you are prohibited from becoming a director, officer, or partner
of any business  organized for profit unless you have obtained the prior written
approval of the Board (or the Board's  designee) and the Code of Ethics Officer.
You should  discuss the  position  with your  supervisor  and the Code of Ethics
Officer  to  determine  whether  it would  involve  a  prohibited  conflict.  If
permissible, the Code of Ethics Officer will help you seek formal approval.

MAY I SERVE AS A DIRECTOR OR OFFICER OF A NON-PROFIT OR CHARITABLE  ORGANIZATION
WITHOUT OBTAINING SPECIFIC APPROVAL?

Bank employees are encouraged to participate in organizations  that are involved
in charitable, educational or community activities and no approval is needed for
your involvement with such activities.

IF A CUSTOMER GIVES ME A CHRISTMAS CARD CONTAINING  MONEY, MUST I REPORT IT? CAN
I KEEP THE MONEY?

The Code  specifically  prohibits  an  employee's  acceptance  of any cash gift.
Unless on your own initiative you immediately  return the money, your receipt of
the gift of money must be reported  immediately to your  supervisor and the Code
of Ethics Officer who will determine  whether the gift should be returned to the
customer or, if appropriate, donated to charity. You cannot keep the money.

IF A  CUSTOMER  OR VENDOR  GIVES ME A PAIR OF GLOVES  WORTH  LESS THAN $200 AS A
CHRISTMAS PRESENT, MUST I REPORT THE GIFT? CAN I KEEP THE GIFT?

Gifts of  nominal  value may be  accepted,  but the  value of any  gifts  from a
customer/vendor  may not exceed in the aggregate  $200 in any one calendar year.
You may,  therefore,  keep  your  Christmas  gift of gloves  (assuming  that the
gloves,  plus any other gifts to you from such  supplier/vendor in the past year
are worth $200 or less), but you may wish to report your receipt of this gift to
the Code of Ethics Officer to avoid misunderstandings.

IF A SUPPLIER OR VENDOR FOR THE BANK OFFERS ME A DISCOUNT OR  REDUCTION IN PRICE
FOR HIS OR HER GOODS OR SERVICES,  MAY I ACCEPT THE DISCOUNT?  MUST I REPORT THE
DISCOUNT?

Reductions  in the price of goods or discounts by a the Bank  supplier  that are
not generally  available to others are treated as gifts,  and are subject to the
$200  limitation and reporting  requirements of the Code.  Discuss  questionable
discounts and price reductions with the Code of Ethics Officer.

An  employee  may not  solicit  any gift or let any gift  affect the  employee's
judgment  concerning the Bank's business even if the gift otherwise is permitted
by the Code.


MAY I ACCEPT A DINNER  INVITATION  OR TICKETS TO A SPORTS  FUNCTION  FROM A BANK
CUSTOMER? MUST I REPORT IT?

To  facilitate   the   discussion  of  Bank   business,   foster  good  business
relationships,  or serve some other  demonstrable  business purpose,  reasonable
entertainment  may be engaged in  between a the Bank  employee  and a current or
prospective customer,  supplier, or vendor. In general, no approval is necessary
if the entertainment's  value is $200 or less or if the customer,  supplier,  or
vendor is present at the event. If the customer,  supplier or vendor will not be
present at the event and if the value  exceeds  $200,  you must first obtain the
approval of your  supervisor and the Code of Ethics  Officer.  Prior approval is
required  for all  out-of-town  sporting  or  other  social  events  even if the
customer,  vendor or supplier  will be present.  In that case,  the employee may
accept  only the ticket to the event and any meals and  entertainment  served or
provided in conjunction with the event.  Payment of transportation to the event,
lodging for the event and meals not directly  provided in  conjunction  with the
event may not be accepted or  expensed.  If in doubt about an  invitation,  seek
approval.  (In many cases the adverse consequences of a conflict of interest can
be eliminated by disclosure.)

A VENDOR HAS INVITED ME TO AN OUT-OF-TOWN  SEMINAR WHERE ENTERTAINMENT WILL ALSO
OCCUR. DO THE RESTRICTIONS  APPLICABLE TO OUT-OF-TOWN SOCIAL EVENTS CONTROL THIS
SITUATION?

Sometimes it is unclear  whether an event is a social or business  event.  There
may be instances  in which  business  discussions  occur at the site of an event
whose  purpose is still  primarily  social.  Factors  that will be  utilized  to
determine  whether the event is social  rather than business are the site of the
event  (i.e.  whether  it  occurs  at a resort or at a site  where  business  is
generally  conducted)  and the types of expense  payments  being  offered by the
third party.  Entertainment and invitations to spouses indicate that the purpose
of the event is social.  Payment of expenses similar to those for which the Bank
will reimburse its own employees indicates that the event is business in nature.
Determination of the appropriateness of the event is a factual inquiry and is to
be made by requesting  the approval of the employee's  immediate  supervisor and
Code of Ethics Officer.

EACH YEAR I RECEIVE  FROM A  CUSTOMER A GIFT OR  ENTERTAINMENT  IN EXCESS OF THE
$200  LIMITATION.  I HAVE RECEIVED THE PROPER  AUTHORIZATION  UNDER THE CODE AND
REPORTED SUCH OCCURRENCE. MUST I REPORT THIS ANNUAL GIFT?

Although you need not secure  authorization  again if the initial  authorization
indicated that the gift or entertainment  was of a continuing  nature,  you must
still report this annual  occurrence  each time you certify your compliance with
the Code.

I HAVE BEEN ASKED TO RUN FOR CITY  COUNCIL.  MAY I RUN?  NEED I ADVISE ANYONE AT
THE BANK?

The Bank fully encourages your civic participation and community involvement and
concern.  We  accordingly  support  your  holding  of a  part-time  elective  or
appointed  office if there is no conflict of interest.  Prior to running for any
office or position,  however,  you must first provide the Code of Ethics Officer
with a full  disclosure  of  information  concerning  the office or  position in
question  and, in most  cases,  an opinion  from the  political  entity's  legal
counsel  stating that your candidacy is not prohibited and that your election or
appointment will not bar the political entity from doing business with the Bank.
In addition, you must have the written approval of your immediate supervisor and
Code of Ethics Officer prior to your accepting any political office.

I UNDERSTAND THAT THE BANK REGULARLY  SELLS REAL ESTATE OWNED.  MAY I, OR ONE OF
MY FAMILY MEMBERS, PURCHASE FORECLOSED REAL ESTATE BEING SOLD BY THE BANK?

No. Property obtained by a Bank subsidiary  through  foreclosure or repossession
may not be  purchased  by any the Bank  employee or any member of an  employee's
immediate family. In addition,  the Bank's Code of Ethics limits the sale of any
Bank property to its employees.  These prohibitions include sales to your family
members as well.  Therefore as a general rule,  you may not purchase any Bank or
subsidiary property subject to sale, whether through repossession,  foreclosure,
or as a result of replacement.

AS PART OF MY JOB, I AM ABLE TO OBTAIN  INFORMATION  NOT AVAILABLE TO THE PUBLIC
CONCERNING THE FINANCIAL CONDITION OF FIRMS/COMPANIES THAT BORROW MONEY FROM THE
BANK. I WOULD LIKE TO MAKE AN INVESTMENT IN SOME OF THESE  FIRMS/COMPANIES.  MAY
I?

The Bank's Code of Ethics  strictly  prohibits the use of nonpublic  information
regarding the Bank, its employees,  customers, or suppliers. Such information is
confidential  and employees may neither disclose such information nor use it for
trading in securities or for other personal gain.

Customer  information obtained through your position at the Bank is confidential
information  that you are strictly  prohibited  from using for your own personal
investments.  Similarly,  you are absolutely  prohibited  from buying or selling
Carver  Bancorp,  Inc.  stock  based upon  nonpublic  information  that you have
obtained  through  your  employment  at the  Bank,  as well as  stocks  of other
entities that are possibly  subject to purchase by the Bank.  Hence,  you cannot
make your proposed investment.

I AM A BRANCH MANAGER AND SEVERAL OF MY CUSTOMERS ARE PUBLICLY TRADED COMPANIES.
IT HAS BEEN  SUGGESTED  THAT I INVEST IN THE STOCK OF ONE OF THE COMPANIES BY MY
CONTACT AT THE COMPANY.  I HAVE NO INSIDE  INFORMATION ABOUT THE COMPANY.  MAY I
INVEST?

You may not invest in your customer's  securities even though you have no inside
information about the company.  You may not do so because no employee may invest
in the securities of a the Bank customer if the employee  participates  in or is
expected to  participate  in or is  responsible  for extensions of credit to the
customer.

WHAT ARE MY RESPONSIBILITIES WITH RESPECT TO BUSINESS INFORMATION AT THE BANK?

Non-public information (such as processes,  programs,  software, customer lists,
and business information and plans) about the Bank or its businesses, employees,
customers,  or  suppliers  is  confidential  and  belongs  to the  Bank  even if
developed by the employee  either  within or outside of the  employee's  area of
responsibility.  This  information  may not be used or  disclosed by an employee
except in connection with the employee's job  responsibilities and documents and
data relating to the information  must be returned to the Bank when the employee
terminates employment.

I AM THINKING  ABOUT  SELLING REAL ESTATE WITH AN AREA REAL ESTATE  COMPANY ON A
PART-TIME BASIS. I WORK FOR THE BANK AS A CUSTOMER SERVICE REPRESENTATIVE, AND I
THINK MY CUSTOMER SERVICE  EXPERTISE WILL REALLY HELP ME SELL HOUSES. IS THERE A
PROBLEM WITH WORKING PART-TIME? MUST I REPORT MY PLANS TO THE BANK?

As a Bank  employee,  you are  prohibited  from engaging in employment  that may
conflict  with the  Bank's  interests  or which in any way  interferes  with the
performance  of your  job  duties.  As an  employee  of the  Bank,  you are also
strictly  prohibited from working for a competitor  financial  institution (e.g.
another  bank,  savings  and  loan  or  mortgage  company),  and you may not use
confidential   information  for  your  own  personal  gain.  As  a  real  estate
agent/broker  and an  employee  of the Bank,  you  would be  placed in  constant
conflict of interest  situations because of the buyers' need to secure financing
and your employment relationship with the Bank; therefore, you may not engage in
such real estate sales activity.

If you have a real  estate  sales or broker's  license,  it must be placed in an
inactive status.



Before  engaging in any part-time  work,  including  sole  proprietorships,  you
should  review what duties your  part-time  job will entail with your  immediate
supervisor  and the Code of Ethics  Officer  to  ensure  that you will not be in
violation of your  responsibilities  under the Code. As a general rule or guide,
you may not perform on a part-time basis any function that you perform as a Bank
employee.  For example,  you may not do  consulting  work that is similar to the
duties you  perform  for the Bank.  Additionally,  if you work  part-time  for a
temporary  agency in addition to your Bank  position,  you may not accept agency
assignments at competing financial institutions,  even if the job function to be
performed is totally different from your job function at the Bank.

AS A CUSTOMER SERVICE  REPRESENTATIVE FOR MANY YEARS, I HAVE GOTTEN TO KNOW MANY
OF THE BANK'S CUSTOMERS WHOM I SERVE.  OCCASIONALLY,  I AM ASKED BY CUSTOMERS TO
SERVE AS THE EXECUTOR FOR THEIR ESTATES AT THEIR DEATH. MAY I?

No. As the  executor of an estate,  you are in a fiduciary  relationship  to the
estate,  which may conflict with your duties and obligations as a Bank employee.
Additionally,  as a the  Bank  employee,  any  problems,  claims,  or  liability
resulting from your role as the executor of a customer's  estate may subject the
Bank to the same claims and  liability  due to the Bank's  relationship  as your
employer.  However,  your  acting in a fiduciary  capacity  for a member of your
immediate family is permitted.

WHAT ARE MY  RESPONSIBILITIES  WITH  RESPECT  TO THE BANK'S  ELECTRONIC  MESSAGE
COMMUNICATIONS SYSTEMS?

Misuse of the Bank's electronic message communications systems is prohibited and
may result in corrective action up to and including termination. Misuse includes
accessing or  distributing  pornographic  or other  distasteful  information  or
materials containing offensive, sexually explicit or harassing language, sending
chain  letters,  or  conducting  excessive  personal  business.  See the  Bank's
Computer and E-Mail Usage Policy for a complete discussion of what constitutes a
misuse of the Bank's electronic message communications systems.

AM I RESPONSIBLE FOR REPORTING POSSIBLE CODE VIOLATIONS?

As a the Bank employee,  you are responsible for reporting to the Code of Ethics
Officer  any  activity  that  you  suspect  may be in  violation  of the  Code's
requirements--whether  the activity  involves you or another the Bank  employee.
Reporting what you regard as a questionable activity will not subject you to any
repercussions with regard to your job, unless you know your report is false. You
may call the  ComplianceLine  at  1-800-399-2305,  use the drop box in the break
room of C level of the Main Office,  or forward  written  correspondence  to the
Chairman of the Finance and Audit  Committee to  anonymously  report a suspected
Code violation.  While some employees may consider reporting on another the Bank
employee as  inappropriate,  the  importance of honesty and integrity  among the
Bank  employees  and its impact on the Bank and the  general  public to whom the
Bank provides financial services cannot be stressed enough.  Anyone who violates
the Code potentially  hurts not only the Bank but also everyone  employed by the
Bank.


AS AN EMPLOYEE OF THE BANK, I PARTICIPATE IN A SALES  INCENTIVE  PLAN. I SUSPECT
THAT MY LAST INCENTIVE  PAYMENT IS MORE THAN THE AMOUNT I HAVE EARNED.  SHOULD I
IGNORE THE DISCREPANCY AND PRESUME THAT IT WILL EVENTUALLY BE CORRECTED?

No. You should inform your manager and the administrator of your incentive plan.
If the matter is not resolved, you should notify the Code of Ethics Officer. Any
breakdown  of  internal  controls  should be  resolved or reported to the Bank's
Chief Auditor.

WHAT ARE THE PENALTIES IF I VIOLATE THE CODE OF ETHICS?

The Code is part of the Bank's  personnel  policies and is therefore  subject to
the disciplinary  procedures set forth in those policies.  Violation of the Code
will subject you to disciplinary action up to and including termination.

I AM CONCERNED THAT OTHERS IN THE BANK WILL FIND OUT THAT I REPORTED A VIOLATION
OF THE CODE OF ETHICS AND THAT THERE WILL BE REPERCUSSIONS TO ME FOR MY REPORT.

The Code of Ethics strictly  prohibits any employer from retaliating  against an
officer,  director,  or  employee  who  reports or causes to report an actual or
suspected activity as defined by the Code. Additionally,  the Code requires that
you  have  the  option  to  remain  anonymous  should  you  choose  and that the
information you supply to the Bank remain confidential to the extent possible to
fully  investigate  the  allegation.  However,  in order to conduct an effective
investigation, it may not be possible to maintain confidentiality and anonymity.