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Advisor Representative Registration, Hiring, and Training
Firm Policy
As a registered investment adviser, CIS maintains and renews its adviser registration on an annual basis through
the Investment Adviser Registration Depository (“IARD”), for the firm, state filings, as appropriate, and investment
adviser representatives (“IARs”).

CIS's policy is to monitor and maintain all appropriate firm and IAR registrations that may be required for providing
advisory services to our clients in any location. CIS monitors the state residences of our advisory clients, and will
not provide advisory services unless appropriately registered as required, or a de minimis or other exemption
exists. The firm’s Chief Compliance Officer (CCO) shall be responsible for handling the registration and supervising
the training of all the Investment Advisor Representatives (IARs) of the firm:

Background
In accordance with the Advisers Act, and unless otherwise exempt from registration requirements, investment
adviser firms are required to be registered either with the Securities and Exchange Commission (SEC) or with the
state(s) in which the firm maintains a place of business and/or is otherwise required to register in accordance with
each individual state(s) regulations and de minimis requirements. The registered investment adviser is required to
maintain such registrations on an annual basis through the timely payment of renewal fees and filing of the firm’s
Annual Updating Amendment.

Individuals providing advisory services on behalf of the firm are also required to maintain appropriate registration
(s) in accordance with each state(s) regulations unless otherwise exempt from such registration requirements. The
definition of investment adviser representative may vary on a state-by-state basis. Supervised persons providing
advice on behalf of SEC-registered advisers are governed by the federal definition of investment adviser
representative to determine whether or not state IAR registration is required. The investment adviser
representative registration(s) must also be renewed on an annual basis through the timely payment of renewal
fees.

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

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:
• The Compliance Officer, or other designated officer, monitors the state residences of our advisory clients,
and the firm and/or its IARs will not provide advisory services unless appropriately registered as required,
or a de minimis or other exemption exists.
• CIS's Compliance Officer, or other designated officer, monitors the firm's and IAR registration
requirements on an on-going as well as a periodic basis.
• Registration filings are made on a timely basis and appropriate files and copies of all filings are maintained
by the Compliance Officer or other designated officer.

Compliance Requirements:
• The CCO will review all new hire U4’s and ensure they are properly registered with the state;
• The CCO will ensure that all new hires and then annually, read, review, and acknowledge at a minimum
the following firm items: Privacy Policy, Code of Ethics, and Policies and Procedures Manual;
• The CCO will maintain a list of all current and past employees of the firm as well as the reason for their
termination as documented in the form U5; and
• The CCO shall be responsible for training and educating supervised persons regarding the Code of Ethics.
Training will occur periodically as needed and all supervised persons are required to attend any training
sessions and read any applicable materials.