Exhibit 14.1

                   CODE OF ETHICS FOR OFFICERS

                                OF

                    RAIKE FINANCIAL GROUP, INC.

                         October 15, 2004

PURPOSE:

Raike Financial Group, Inc. (the  "Company")  has established the
following Code of Ethics (this "Code") in compliance with the
Sarbanes-Oxley Act of 2002 to ensure the continuing integrity of
the Company's  financial reporting  and to protect the interests
of its  shareholders,  creditors and those  with  which the
Company  conducts  business.  This Code sets forth specific
policies to guide the Company's principal executive officer and
senior financial officers in the performance of their duties.

APPLICABILITY:

This Code shall apply to each of the following officers of the
Company (collectively, the "Covered Persons"):

      Principal Executive Officer
      Principal Financial Officer
      Principal Accounting Officer or Controller
      Persons(s) performing similar functions

STANDARDS OF CONDUCT:

To the best of their knowledge and ability, each Covered Person
shall:

  1.  Act with honesty and integrity, in good faith, with
      due care, with diligence and in an ethical manner;

  2.  Exercise independent judgment;

  3.  Avoid actual or apparent conflicts of interest in
      both personal and professional relationships, always
      distinguishing between personal, private interests and
      those interests of the Company, not involving the
      Company in any transaction where a conflict is or may
      be present without prior approval of the Company's Board
      of Directors (the "Board");

  4.  Provide full, fair, accurate, objective, timely and
      understandable disclosures in internal reports and
      documents, as well as reports and documents that the
      Company files with, or submits to, the Securities and
      Exchange Commission (the "SEC") and in other public
      communications made by the Company;

  5.  Comply with applicable laws, rules and regulations of
      federal, state and local governments and other appropriate
      regulatory agencies governing the conduct or operations
      of the Company;

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  6.  Take measures to achieve responsible use of and control
      over the Company's assets, resources and information
      employed by, or entrusted to, him or her;

  7.  Respect the confidentiality of information acquired
      in the course of employment with the Company, except
      when authorized or otherwise legally obligated to
      disclose such information, and do not use  confidential
      information acquired in the course of the Company's
      business for personal advantage; and

  8.  Proactively promote ethical and honest behavior within
      the Company.

FINANCIAL RECORDS AND PERIODIC REPORTS:

Covered Persons shall establish and manage the  Company's
transactional and
reporting systems and procedures to provide reasonable assurance
that:

  1.  Business transactions are properly authorized and
      completely, timely and accurately recorded on the
      Company's  books and records in accordance with generally
      accepted accounting principles in the United States,
      rules promulgated by the SEC, regulatory requirements
      and established policies of the Company; and

  2.  The retention or proper disposal of the Company's
      records is in accordance with established Company
      financial policies and applicable legal and regulatory
      requirements.

REPORTING:

Each Covered Person shall  promptly,  upon becoming aware
thereof, bring to the attention of the CEO (subject to the
Company's confidential and anonymous complaint process which
may require such information to go only to the Company's Audit
Committee) and all members of the Audit Committee:

  1.   Any act or any violation of this Code by any Covered
       Person or any act by any other person or entity
       (whether or not subject to this Code) that would be a
       violation of this Code if such person or entity were a
       Covered Person;

  2.   Any recognized potential conflict of interest of the
       Covered Person or any other employee or agent of the
       Company;

  3.   Any information that indicates that any disclosures
       made or to be made by the Company in its public
       filings were materially false or misleading, omitted
       to state a material fact or omitted to state a
       material fact necessary in order to make a statement
       in such filing not false or misleading;

  4.   Any information concerning a material violation by


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       the Company or any employee or agent of the Company
       or by any other person or entity of laws, rules or
       regulations, including, without limitation,
       securities laws, rules and regulations, applicable
       to the Company or its business or operations;

  5.   Any information concerning significant deficiencies
       in the design or operation of the Company's internal
       controls which could adversely affect the Company's
       ability to record,  process, summarize or report
       financial data; and

  6.   Any information concerning any fraud, whether or
       not material, that involves management or other
       employees who have a significant role in the
       Company's financial reporting, disclosures or
       internal controls.

ENFORCEMENT:

The Board shall determine appropriate actions to be taken in the
event of violations of this Code.  Such actions shall be reasonably
designed to deter wrongdoing and to promote accountability for not
adhering to this Code.

A failure to report apparent violations, covering up violations or
apparent violations, retaliating against or disciplining a person
for reporting a violation or apparent violation, or obstructing an
investigation of an alleged or apparent violation shall also be a
violation of this Code.

WAIVERS:

The Board shall have the sole and absolute discretionary authority
to approve any amendment to, or waiver (including implicit waiver)
from, any provision of this Code.  Any change of this Code, and any
waiver (including implicit waiver) and the grounds for such waiver
for a Covered Person, shall be timely disclosed through a filing
with the SEC on Form 8-K or other method permitted by the rules
of the SEC.

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If there are any questions involving the application of this Code,
guidance should be sought from the Company's legal counsel.


BOARD OF DIRECTORS
RAIKE FINANCIAL GROUP, INC.

By _________________________
      Chairman


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