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Accuracy of Disclosures Made to Investors, Clients, and Regulators

The CCO is responsible for the accuracy of all disclosures made to investors, clients, and regulators and will review
Form ADV 2A/2B update requirements are outlined in that section of this manual. Where third party disclosure
documents are involved, the CCO will verify that these documents are legitimate documents from the third party.
CIS will notify all clients receiving these third party documents that CIS has only verified the legitimacy and origin of
the documents but has NOT verified or analyzed the information contained therein. The client will be instructed to
conduct their own investigations to verify the information contained in each document including but not limited to
a due diligence investigation.

Account Statements
IARs will review client account statements to ensure their accuracy.

Advertisements
All advertisements are reviewed to ensure their accuracy, specifically in regards to any performance claims.

Solicitors
If and when CIS uses solicitors the CCO will require pre-approval of all advertisements, marketing material, and all
marketing approaches in use by the solicitor prior to solicitation activities and at least quarterly thereafter. The
CCO will also verify that all Solicitor Agreements are up to date and current and that all Solicitors are delivering
copies of CIS’s Client Brochure (Form ADV 2A and 2B) to each client solicited.