Exhibit 99.2 to Form 10-KSB

Code of Ethics for our Principal Executive Officer, Principal Financial Officer,
Principal  Accounting  Officer  or  Controller,  or Persons  Performing  Similar
Functions:

                    CORNERSTONE MINISTRIES INVESTMENTS, INC.
                             CODE OF ETHICS FOR THE
            PRINCIPAL EXECUTIVE OFFICER AND SENIOR FINANCIAL OFFICERS
                             PURPOSE AND APPLICATION

The  purpose  of this Code of Ethics for the  Principal  Executive  Officer  and
Senior Financial  Officers (the "Code") of Cornerstone  Ministries  Investments,
Inc. (the  "Company") is to help deter  wrongdoing,  promote  honest and ethical
conduct and ensure  compliance  with  applicable  governmental  laws,  rules and
regulations,  including  Section 406 of the  Sarbanes-Oxley  Act of 2002 and the
rules of the Securities and Exchange  Commission  promulgated  there under.  The
Code is applicable to the Company's principal executive officer (Chief Executive
Officer),  principal  financial  officer  (Chief  Financial  Officer)  principal
accounting  officer or controller,  or persons performing similar functions (the
"Senior  Officers").  The Senior  Officers are expected to read,  understand and
comply  with the Code.  Nothing in the Code or in other  related  communications
(oral  or  written)  creates  or  implies  an  employment  contract  or  term of
employment.

HONEST AND ETHICAL CONDUCT

The Company  expects the Senior  Officers to act with the highest  standards  of
honest and ethical  conduct while working at or  representing  the Company.  The
Company  considers  honest and ethical  conduct to be conduct  that is free from
fraud and that  conforms to accepted  professional  standards  of conduct.  This
includes  the  ethical  handling  of actual or  apparent  conflicts  of interest
between personal and professional relationships,  as discussed in more detail in
the section entitled "Conflicts of Interest" below.

In all cases, if you are unsure about the appropriateness of an event or action,
please seek  assistance in interpreting  the  requirements of these practices by
contacting the Company's Chief  Financial  Officer (or, in the case of the Chief
Executive Officer or Chief Financial Officer, the Company's Audit Committee).

CONFLICTS OF INTEREST

The Code  requires the Senior  Officers to ethically  handle  actual or apparent
conflicts  of  interest  between  personal  and  professional  relationships.  A
conflict of interest  exists  where the  interests  or benefits of one person or
entity conflict with the interests or benefits of the Company.

Some examples of actual or apparent conflicts of interests include:

     o    outside  employment  or  directorships  with  an  important  customer,
          supplier or  competitor  of the  Company,  other than on behalf of the
          Company;

     o    making  significant  financial  investments in an important  customer,
          supplier  or  competitor  of the  Company  without  approval  from the
          Company; or

     o    receiving  significant  improper personal benefits from another person
          or  entity  as a result  of the  Senior  Officer's  position  with the
          Company and with the intent to  inappropriately  influence  the Senior
          Officer's decision-making on behalf of the Company.

Because  other  conflicts  of interest  may arise,  it would be  impractical  to
attempt to list all possible situations.  If a proposed transaction or situation
raises any questions or doubts for you, you should  consult the Company's  Chief
Financial  Officer  (or,  in the case of the Chief  Executive  Officer  or Chief
Financial Officer, the Company's Audit Committee).

The  Company's  policy  requires  that a Senior  Officer  disclose  any material
transaction or relationship  that could reasonably be expected to give rise to a
conflict  of  interest to the Chief  Financial  Officer  (or, in the case of the
Chief  Executive  Officer  or  Chief  Financial  Officer,  the  Company's  Audit
Committee) and that the Company's  Audit  Committee give prior approval before a
Senior Officer enters into any such material transaction or relationship.

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FULL, FAIR, TIMELY AND UNDERSTANDABLE DISCLOSURE

The Senior  Officers  must take  appropriate  steps to attempt to provide  full,
fair,  accurate,  timely and understandable  disclosure in reports and documents
that the  Company  files  with,  or submits  to,  the  Securities  and  Exchange
Commission and in other public communications made by the Company.

COMPLIANCE WITH APPLICABLE GOVERNMENTAL LAWS, RULES AND REGULATIONS

The Senior Officers must seek to comply with applicable governmental laws, rules
and  regulations.   Violations  of  applicable   governmental  laws,  rules  and
regulations  may subject the Senior  Officers  to  individual  criminal or civil
liability, as well as to discipline by the Company.

INTERNAL REPORTING OF VIOLATIONS OF THE CODE

Part of a Senior  Officer's  responsibilities  is to help enforce this Code. The
Senior  Officers  should report  violations  of the Code to the Chief  Financial
Officer or, if the violations of the Code involve the Chief Financial Officer or
Chief Executive Officer, to the Company's Audit Committee.

Senior Officers must cooperate with any internal or external  investigations  of
possible  violations  of the Code.  Discrimination,  retaliation  or  harassment
against  any person who has in good faith  reported a  violation  or a suspected
violation  of  the  Code,  or  against  any  person  who  is  assisting  in  any
investigation or process with respect to such a violation, is prohibited.

ACCOUNTABILITY FOR ADHERENCE TO THE CODE

Complying with the Code is a condition of employment  with the Company,  and the
Company will take  appropriate  action  against any Senior Officer whose actions
are found to violate the Code.  Disciplinary  actions may include termination of
employment at the Company's  sole  discretion.  Where the Company has suffered a
loss,  it  may  pursue  its  remedies   against  the   individuals  or  entities
responsible.  Where laws have been violated,  the Company will  cooperate  fully
with the appropriate governmental authorities.

CHANGES OR WAIVERS OF THE CODE

The Company is committed to continuously reviewing and updating its policies and
procedures.  Therefore,  the Code is subject  to  modification.  Any  changes or
waivers  of the Code must be  approved  by the  Company's  Audit  Committee  and
disclosed to the extent required by applicable law.


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