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Investment Processes

Policy
As a registered adviser, and as a fiduciary to our advisory clients, CIS is required, and as a matter of policy, obtains
background information as to each client's financial circumstances, investment objectives, investment restrictions
and risk tolerance, among many other things, and provides its advisory services consistent with the client's
objectives, etc. based on the information provided by each client. CIS does advise clients in the use of complex
products. As such CIS has specific policies and procedures concerning these products which may include the use of
Exchange Traded Funds.

Background
The U.S. Supreme Court has held that Section 206 (Prohibited Activities) of the Investment Advisers Act imposes a
fiduciary duty on investment advisers by operation of law (SEC v. Capital Gains Research Bureau, Inc., 1963). Also,
the SEC has indicated that an adviser has a duty, among other things, to ensure that its investment advice is
suitable to the client's objectives, needs and circumstances, (SEC No-Action Letter, In re John G. Kinnard and Co.,
publicly available 11/30/1973). Every fiduciary has the duty and a responsibility to act in the utmost good faith and
in the best interests of the client and to always place the client's interests first and foremost. As part of this duty, a
fiduciary and an adviser with such duties, must eliminate conflicts of interest, whether actual or potential, or make
full and fair disclosure of all material facts of any conflicts so a client, or prospective client, may make an informed
decision in each particular circumstance.

Responsibility
The firm's investment professionals responsible for the particular client relationship have the primary
responsibility for determining and knowing each client's circumstances and informing the money manager, so he
can manage the client's portfolio consistent with the client's objectives. CIS's designated officer has the overall
responsibility for the implementation and monitoring of our investment processes policy, practices, disclosures
and recordkeeping for the firm.

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 obtains substantial background information about each client's financial circumstances, investment
objectives, and risk tolerance, among other things, through an in-depth interview and information
gathering process which includes client profile or new account forms.
• Advisory clients may also have and provide written investment policy statements or written investment
guidelines that the firm reviews, approves, and monitors as part of the firm's investment services, subject
to any written revisions or updates received from a client.
• CIS provides the firm's Form ADV Part II to all prospective clients which discloses the firm's advisory
services, fees, conflicts of interest and portfolio/supervisory reviews and investment reports provided by
the firm to clients.
• CIS may provide periodic reports to advisory clients which include important information about a client's
financial situation, portfolio holdings, values and transactions, among other things.
• The firm may also provide performance information to advisory clients about the client's performance,
which may also include a reference to a relevant market index or benchmark.
• Investment professionals may also schedule client meetings on a periodic basis, or request basis, to
review a client's portfolio, performance, market conditions, financial circumstances, and investment
objectives, among other things, to confirm the firm's investment decisions and services are consistent
with the client's objectives and goals. Documentation of such reviews should be made in the client file
when needed.
• Client relationships and/or portfolios may be reviewed on a more formal basis on a quarterly or other
periodic basis by designated supervisors or management personnel.