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Customer Complaint Policy
Firm Policy
As a registered adviser, and as a fiduciary to our advisory clients, our firm has adopted this policy, which requires a
prompt, thorough and fair review of any advisory client complaint, and a prompt and fair resolution which is
documented with appropriate supervisory review. The firm’s Chief Compliance Officer (CCO) shall be responsible
for handling complaint reviews.

Background
Based on an adviser's fiduciary duty to its clients and as a good business practice of maintaining strong and long
term client relationships, any advisory client complaints of whatever nature and size should be handled in a
prompt, thorough and professional manner. Regulatory agencies may also require or request information about
the receipt, review and disposition of any written client complaints.

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 maintains a Complaint File for any written complaints received from any advisory clients.
• Any person receiving any written client complaint is to forward the client complaint to CIS's designated
officer.
• Upon the receipt of any complaint, the CCO or appropriate person will contact CIS’s independent
compliance company and forward them any relevant information.
• If appropriate, the designated officer will promptly send the client a letter acknowledging receipt of the
client's complaint letter indicating the matter is under review and a response will be provided promptly.
• The CCO will work with the compliance company to resolve the complaint.
• The designated officer will forward the client complaint letter to the appropriate person or department,
depending on the nature of the complaint, for research, review and information to respond to the client
complaint.
• The designated officer will then either review and approve or draft a letter to the client responding to the
client's complaint and providing background information and a resolution of the client's complaint. Any
appropriate supervisory review or approval will be done and noted.
• The designated officer will maintain records and supporting information for each written client complaint
in the firm's complaint file.
• The CCO and the compliance company work together to determine if notification of any regulatory
agencies is required.

Compliance Requirements:
• The CCO will review all complaints immediately as they are made by clients;
• The CCO will communicate with a client via telephone, face-to-face meetings, and/or email to resolve all
complaints and client issues;
• The CCO will maintain a complaint file in the main filing cabinet. This file will contain each client
complaint, including, but not limited to, any letter, email, or document from a client who has filed a
complaint; any letter, email, or document from any agency regarding the complaint; any communication
sent from the IA to any client, agent, agency, or third party regarding each complaint; and documentation
of how each complaint was resolved.
• CCO will contact firm’s supervisory personnel if appropriate or necessary to assure that all complaints are
settled or resolved and that no complaints are left “dangling” or incomplete. No complaint should be left
unresolved and the date the complaint is “closed” should be noted on the complaint filing.