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Wrap Fee Sponsor

Policy
CIS, sponsors a wrap fee program, defined as any advisory program under which a specified fee or fees not based
directly upon transactions in a client’s account is charged for investment advisory services (which may include
portfolio management or advice concerning the selection of other investment advisers) and the execution of client
transactions. A separate wrap account brochure will be provided to clients of CIS that participate in the wrap fee
program. It will be delivered to clients 48 hours before a client relationship is established with CIS. The wrap fee
brochure will be included in CIS’s ADV filings.

Background
A wrap fee program is defined as any program under which any client is charged a specified fee or fees not based
directly upon transactions in a client’s account for investment advisory services (which may include portfolio
management or advice concerning the selection of other investment advisers) and execution of client transactions.
The wrap fee does not include postage and handling fees or regulatory fees.

The Wrap fee program does not include custody services as part of the all-inclusive services in the program. The
custodian effects all security transactions for CIS in the wrap fee account.

Responsibility
John Riley has the responsibility for the implementation and monitoring of our wrap fee policy that the firm
prohibits sponsoring any wrap fee programs unless appropriately approved and all regulatory requirements are
met.

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 designated officer monitors the firm's businesses and advisory services, including periodic reviews of
the firm's Form ADV and disclosures to prohibit any arrangements for sponsoring any wrap fee program.
• CIS's designated officer also monitors the firm's advisory services to ensure that any arrangements to
sponsor any wrap fee program would only be allowed after appropriate management approvals,
disclosures and meeting regulatory requirements.