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• CIS must deliver the supplement for a supervised person before or at the time that supervised person
begins to provide advisory services to a client.
• CIS also must deliver to clients any update to the supplement that amends information in response to
Item 3 of Part 2B (disciplinary information). Such an amendment can be in the form of a “sticker” that
identifies the information that has become inaccurate and provides the new information and the date of
the sticker.

As a fiduciary, CIS has a continuing obligation to inform your clients of any material information that could affect
the advisory relationship. As a result, between annual updating amendments CIS must disclose material changes to
clients even if those changes do not trigger delivery of an updated supplement. CIS may have a supervised person
deliver supplements (including his own) on your behalf.

Failure to properly distribute your Form ADV 2A & 2B, as required by this instruction, is a violation of various
federal and/or state rules and statutes and could lead to your registration being revoked.

Distribution Requirements
The firm’s Chief Compliance Officer (CCO) shall ensure all new firm clients are given a copy of the firm’s Form ADV
2A and applicable 2B brochures at or before the contract signing.

The firm’s CCO shall ensure that at least annually all clients are offered in writing and free of charge the firm’s
current ADV 2A, ADV 2A updates, and any applicable individual ADV 2B updates.

The firm’s CCO shall also ensure that any required interim filings to the firm’s ADV 2A and individual ADV 2B filings
are delivered to the client as described above.