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Directed Brokerage

Policy
CIS's policy and practice is to not accept advisory clients' instructions for directing a client’s brokerage transactions
to a particular broker-dealer. It is the policy of CIS to execute trades for RIA clients through our RIA custodian.

Full disclosure of charges incurred by clients of CIS for executions effected via the RIA custodian will be made
through CIS’s ADV 2A filing and investment advisory contract.

Background
Clients of CIS may not direct advisers to use a particular broker-dealer under various circumstances, including
where a client has a pre-existing relationship with the broker or participates in a commission recapture program,
among other situations. Advisers may also elect not to exercise brokerage discretion and, therefore, require clients
to direct brokerage. Advisers should recommend to clients the use of broker-dealers providing reasonable,
competitive and quality brokerage services and advise clients if a client's directed broker does not provide
competitive and quality services.

Responsibility
John Riley has the responsibility for the implementation and monitoring of our directed brokerage policy that the
firm does not accept client instructions for directing brokerage to a particular broker-dealer.

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 the acceptance of client instruction for the direction of brokerage has been
communicated to relevant individuals including management, traders, and portfolio managers, among
others.
• The firm's advisory agreements and Disclosure Brochures (Form ADV Part 2) disclose that the firm has
discretion as to the selection of broker-dealers and may disclose the firm's policy of not accepting client
directed brokerage instructions.
• John Riley periodically monitors the firm's advisory services and trading practices to help ensure no
directed brokerage instructions exist or are accepted by the firm.
• In the event of any change in the firm's policy, any such change must be approved by management, and
any directed brokerage instructions would only be allowed after appropriate reviews and approvals,
received in writing, with appropriate disclosures made, regulatory requirements met and proper records
maintained.