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Compliance Procedures

Portfolio Management Processes
Allocation of Investment Opportunities Among Clients
It is CIS’s policy, to the extent practical, to allocate investment opportunities to clients over a period of time on a
fair and equitable basis relative to other clients. The firm CCO reviews client accounts at least quarterly for
equitable treatment and reviews its Allocation practices annually.

Consistency of Portfolios with Clients’ Investment Objective
CIS provides Discretionary account management on a continuous basis. Subject to a grant of discretionary
authority, CIS, shall invest and reinvest the securities, cash or other property held in the client’s account in
accordance with the client’s stated investment objectives as identified by the client during initial interviews and
information gathering sessions. CIS offers Model Portfolios from which the client chooses those that best fit their
objectives and risk tolerance. These are listed in Exhibit I (the Investment Policy Statement “IPS”) of the
Investment Advisor Contract (IAC) or the Financial Planning Agreement. The IAC is reviewed and updated at least
annually.

Disclosures By the Adviser
CIS operates on a discretionary basis pursuant to authorization provided in the executed agreement for services
(IAC), which is maintained in the relevant client file. Portfolio management services will not be rendered prior to
the client entering into this written agreement for services (IAC). The only person that manages client portfolios is
the money manager, John Riley.

When a transaction takes place, the money manager will create the order, route it to the custodian who will then
execute the trade. CIS only trades through the RIA’s custodian, which is disclosed to the client.

CIS ensures that client accounts are managed according to the investment objectives of the Model(s) chosen by
the client via the following process: CIS allocates assets according to the current allocation of the Model. If the
client’s asset classes are higher or lower than the target allocation of the Model, then the Money manager may
adjust the portfolio accordingly. The asset allocations of the Models are not static, so there may be times when the
money manager anticipates increasing or decreasing the target allocation if he believes that the asset class may be
over valued or under valued.

Valuation of Securities
CIS will use information provided by the client’s custodian as its main pricing source for purposes of valuing client
portfolios, both for fee billing and investment performance calculation purposes.

Account Statements
The custodian holding the client’s funds and securities will send the client a confirmation of every securities
transaction and a brokerage statement at least quarterly.

Additional information related to the CIS’s portfolio management and trading procedures is detailed in the
executed agreement for services (IAC) located in the specific client file, and in CIS’s Form ADV 2.

Sub-Adviser / Money Manager Review
If CIS utilizes or recommends the services of sub-advisers or money managers for account/portfolio management
services, prior to (and on an ongoing basis) referring clients to any such entity, CIS will conduct a due diligence
review of the adviser or money manager. The review will consist of a presentation by the sub-adviser directly or
indirectly to CIS, additional gathering of material regarding the sub-adviser or money manager, including their
Form ADV, registration status of firm, etc. Once all information has been collected, CIS will review the materials,
and determine if the sub-adviser or manager should be utilized or continue to be utilized for account management
services. Records of the review and final decision will be maintained in CIS’s compliance files.

Applicable Regulatory Restrictions
The size and complexity of various offerings will dictate regulatory registration requirements and restrictions. For
example, offerings classified as 506 Reg D filings (registration filings made under Rule 506 or Regulation D) are filed
by completing and submitting a “Form D” to the SEC. These securities can only be offered to “accredited investors”
as defined in Rule 501 of Regulation D. There are numerous regulator rules and statutes covering all types of