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Record Retention Requirements

The firm’s CCO shall ensure that all records are kept readily accessible for at least two years and kept at least five
years either on-site or at alternative location.

Corporate Records
Policy
As a registered investment adviser and legal entity, CIS has a duty to maintain accurate and current “Organization
Documents.” As a matter of policy, CIS maintains all Organization Documents, and related records at its principal
office. All Organization Documents are maintained in a well-organized and current manner and reflect current
directors, officers, members or partners, as appropriate. Our Organization Documents will be maintained for the
life of the firm in a secure manner and location and for an additional three years after the termination of the firm.

Background
Organization Documents, depending on the legal form of an adviser, may include the following, among others:
• Articles of Incorporation, By-laws, etc (for corporations)
• Agreements and/or Articles of Organization (for limited liability companies)
• Partnership Agreements and/or Articles (for partnerships and limited liability partnerships)
• Charters
• Minute Books
• Stock certificate books/ledgers
• organization resolutions
• any changes or amendments of the Organization Documents

Responsibility
John Riley has the responsibility for the implementation and monitoring of our Organization Documents policy,
practices, and recordkeeping.

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's designated officer will maintain the Organization Documents in CIS's principal office in a secure
location.
• Organization Documents will be maintained on a current and accurate basis and periodically reviewed and
updated by the designated officer so as to remain current and accurate with CIS's regulatory filings,
among other things.