Item 2. Code of Ethics

The Board of Directors/Trustees of First Investors Funds ("Board") has
adopted a Code of Ethics that applies to the First Investors Funds'
("Funds") principal executive officer, principal financial officer,
principal accounting officer or controller, or persons performing
similar functions, regardless of whether these individuals are employed
by the Funds or a third party.  The Code of Ethics is attached to this
report as Exhibit A.

During the period of the report, there have been no amendments to the
Code of Ethics or waivers, implicit or otherwise, from its provisions.