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Compliance Requirements
The firm’s Chief Compliance Officer (CCO) is responsible for the following:
• Ensuring that this statement is followed, and if any soft dollar arrangements not listed here are created,
that the statement is promptly updated to properly reflect this as well as the firm’s updated ADV Form
2A;
• Monitoring all soft dollar arrangements to ensure they fall within the scope of SEC or State requirements;
• Making sure that the firm receives an annual soft dollar statement from any broker-dealer with whom the
firm has a soft dollar arrangement;
• Keeping statements of any products and/or services received for soft dollars;
• Ensuring the best execution of securities transactions when they arrange for or execute trades on behalf
of clients and customers.

Procedure
CIS has adopted various procedures to implement the firm's policy and reviews to monitor and ensure the
firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the
following:
• CIS's policy of prohibiting utilizing any research, and research-related products or services has been
communicated to relevant individuals including management, traders and portfolio managers, among
others.
• The firm's policy is appropriately disclosed in the firm's Form ADV Part II/Disclosure Document.
• John Riley periodically monitors the firm's business relationships and advisory services to ensure no
research services or products are being obtained on a soft dollar basis.
• In the event of any change in the firm's policy, any such change must be approved by management, and
any soft dollar arrangements would only be allowed after appropriate reviews and approvals, disclosures,
meeting regulatory requirements and maintaining proper records.

Review Process
Reviews of the firm’s soft dollar arrangements are to be conducted by the CCO on an annual basis at a minimum.

Interim reviews may be conducted in response to changes in the firm’s soft dollar arrangements.