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Performance

Policy
CIS, as a matter of policy and practice, does not prepare and distribute various performance information relating
to the investment performance of the firm or an aggregate of advisory clients. We believe that aggregated
performance information could be misleading as clients come and go at various times and each will have a
different experience in a portfolio depending on their timing and time in the portfolio.

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However, CIS has contracted an independent 3 party to supply performance reporting on a per household basis
or on a per account basis with information they have obtained directly from the custodian. This would be for the
private use of that client only. CIS's policy requires that any performance information and materials must be
truthful and accurate, and prepared and presented in a manner consistent with applicable rules and regulatory
guidelines and reviewed and approved by a designated officer. CIS's policy prohibits any performance information
or materials that may be misleading, fraudulent, deceptive and/or manipulative.

Background
An investment adviser's performance information is included as part of a firm's advertising practices which are
regulated by the SEC under Section 206 of the Advisers Act, which prohibits adviser from engaging in fraudulent,
deceptive, or manipulative activities. The manner in which investment advisers portray themselves and their
investment returns to existing and prospective clients is highly regulated. These standards include how
performance is presented. SEC Rule 206(4)-1 proscribes various advertising practices of investment advisers as
fraudulent, deceptive or manipulative and various SEC no-action letters provide guidelines for performance
information. Due to the complicated nature of the regulations and the measurement of aggregated returns,
Cornerstone does not produce them.

Responsibility
John Riley has the responsibility for implementing and monitoring our policy for the preparation, presentation,
review and approval of any performance information to ensure any materials are consistent with our policy and
regulatory requirements. This designated person is also responsible for maintaining, as part of the CIS's books and
records, copies of all performance materials, including the supporting records to demonstrate the calculation of
any performance information for the entire performance information period consistent with applicable
recordkeeping requirements, as well as records of reviews and approvals.

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:
• To ensure credibility and integrity and safeguard against any inaccuracy or miscalculation, CIS only utilizes
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performance reports from an independent 3 party that receives the data directly from the custodian.
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The 3 party has control over the entire process from daily valuations, daily reconciliation and calculation
of performance reports.
• All performance information and materials must be reviewed and approved prior to use by a designated
officer, the President or another officer of the firm (other than the individual who prepared such
material), who is familiar with applicable rules and standards for performance advertising.
• The CCO and CIS’ outside, independent compliance company periodically reviews the performance
reports.
• Each employee is responsible for ensuring that approved materials are not used or modified without the
express written authorization of the designated officer.
• The designated officer is responsible for maintaining copies of any performance materials and supporting
documentation for the calculation of performance materials.
• From time to time, a client may request a simple point A to point B valuation change. This report is done
by the CCO and includes a disclosure that only the custodian’s reports are the most accurate and this
report is just a point A to Point B calculation without consideration to time value of money or weighted
value of the account. In short, it is an estimate only.