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Advisory Agreement
Policy
CIS's policy requires a written investment advisory agreement for each client relationship which includes a
description of our services, discretionary/non-discretionary authority, advisory fees, important disclosures
concerning our trade execution and custodial relationships for clients whose assets we manage and other terms of
our client relationship. Where appropriate, John Riley may waive this requirement. CIS's advisory agreements meet
all appropriate regulatory requirements and contain a non-assignment clause and do not contain any “hedge
clauses.”

As part of CIS's policy, the firm also obtains important relevant and current information concerning the client’s
identity, occupation, financial circumstances and investment objectives, among many other things, as part of our
advisory and fiduciary responsibilities.

Background
Written advisory agreements form the legal and contractual basis for an advisory relationship with each client and
as a matter of industry and business best practices provide protections for both the client and an investment
adviser. An advisory agreement is the most appropriate place for an adviser to describe its advisory services, fees,
liability, and disclosures for any conflicts of interest, among other things. It is also a best business practice to
provide a copy of the advisory agreement to the client and for the agreement to provide for all client financial and
personal information to be treated on a confidential basis.

Responsibility
John Riley has the responsibility for the implementation and monitoring of the firm’s advisory agreement policy,
practices, disclosures and recordkeeping.

Procedure
CIS has adopted 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 advisory agreements and advisory fee schedules, and any changes, for the firm’s services are
approved by management.
• The fee schedules are periodically reviewed by CIS to be fair, current and competitive.
• A designated officer, or the Compliance Officer, periodically reviews the firm’s disclosure brochure,
marketing materials, advisory agreements and other material for accuracy and consistency of disclosures
regarding advisory services and fees.
• Performance-based fee arrangements, if any, are appropriately disclosed, reviewed and approved by the
designated officer and/or management.
• Written client investment objectives or guidelines are obtained through the new account form and any
restrictions are noted on the client's advisory agreement.
• Client investment objectives or guidelines are monitored on an on-going and also periodic basis for
consistency with client investments/portfolios.
• Any solicitation/referral arrangements and solicitor/referral fees must be in writing, reviewed and
approved by the designated officer and/or management, meet regulatory requirements and appropriate
records maintained.
• Any additional compensation arrangements are to be monitored by the designated officer, or Compliance
Officer, approved and disclosed with appropriate records maintained.