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Reviews of Inverse ETF positions
The CCO or designated individual will review each client portfolio holding inverse ETFs at least quarterly for post
purchase suitability. Reviews will be more frequent under circumstances such as; market, economic, political or
client needs, among other factors. Any communication from the CCO that directs an inverse ETF review will be
immediately responded to by all affected IAR of the firm. Factors mentioned in the post purchase suitability
section will also impact the review of an inverse ETF position in a client portfolio.

Mutual Fund Share Class Selection Policy
Firm Policy
When recommending the purchase of mutual funds to clients, the firm’s policy is to recommend that clients
purchase the least expensive mutual fund share class available and to disclose material conflicts of interest
including the receipt of compensation for recommending mutual funds.

The firm will assess what mutual fund share classes are available to its clients to determine the least expensive
share class taking into consideration the client’s needs and anticipated activity in the account. Periodically, the
firm will assess whether previously recommended share classes continue to be the least expensive. If not, the firm
will determine whether it is in the best interest of its clients to convert clients to the lower cost share class.

In addition, the firm has disclosed in its ADV Part 2 that it does not recommend open end mutual funds. In the rare
occasion that we would, it would only be an institutional share class.

Trading Practices
Policy
As an adviser and a fiduciary to our clients, our clients’ interests must always be placed first and foremost, and our
trading practices and procedures prohibit unfair trading practices and seek to disclose and avoid any actual or
potential conflicts of interests or resolve such conflicts in the client’s favor.

Our firm has adopted the following policies and practices to meet the firm’s fiduciary responsibilities and to ensure
our trading practices are fair to all clients and that no client or account is advantaged or disadvantaged over any
other.

Also, CIS's trading practices are generally disclosed in our Disclosure Document provided to prospective clients and
annually offered to clients.

Background
As a fiduciary, many conflicts of interest may arise in the trading activities on behalf of our clients, our firm and our
employees, and must be disclosed and resolved in the interests of the clients. In addition, securities laws, insider
trading prohibitions and the Advisers Act, and rules thereunder, prohibit certain types of trading activities.

Aggregation
The aggregation or blocking of client transactions allows an adviser to execute transactions in a more timely,
equitable, and efficient manner and seeks to reduce overall commission charges to clients.

Our firm’s policy is to aggregate client transactions where possible and when advantageous to clients. In these
instances clients participating in any aggregated transactions will receive an average share price and transaction
costs will be shared equally and on a pro-rata basis.

In the event transactions for an adviser, its employees or principals (“proprietary accounts”) are aggregated with
client transactions, conflicts arise and special policies and procedures must be adopted to disclose and address
these conflicts.

Allocation
As a matter of policy, an adviser's allocation procedures must be fair and equitable to all clients with no particular
group or client(s) being favored or disfavored over any other clients.