This study reports the results of an international qualitative study conducted to inform the process of revising the Commission on Rehabilitation Counselor Certification's Code of Professional Ethics for Rehabilitation Counselors. The online survey gathered information regarding ethical dilemmas from a sample of certified rehabilitation counselors and Canadian certified rehabilitation counselors. In sum, 240 participants responded to an open-ended survey regarding current or recent ethical dilemmas and anticipated ethical dilemmas in the near future. Because of the functional purpose of the data set, a qualitative content analysis was performed with open coding guided by the structure of the standards outlined in the 2001 "Code". Implications for "Code" revision and ethics governance are discussed. (Contains 3 tables.)