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Agency Cross Transactions

Policy
CIS's policy and practice is to NOT engage in any agency cross transactions and our firm’s policy is appropriately
disclosed in Form ADV Part 1 and II responses.

Background
An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to
a transaction in which the investment adviser, or any person controlled by or under common control with the
investment adviser, acts as broker for both the advisory client and for another person on the other side of the
transaction (SEC Rule 206(3)-2(b)). Agency cross transactions typically may arise where an adviser is dually
registered as a broker-dealer or has an affiliated broker-dealer. Agency cross transactions are permitted for
advisers only if certain conditions are met under Advisers Act rules including prior written consent, client
disclosures regarding trade information and annual disclosures, among other things.

Responsibility
John Riley has the overall responsibility for implementing and monitoring our policy of not engaging in any agency
cross transactions.

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:
• CIS policy of prohibiting any agency cross transactions for advisory clients has been communicated to
relevant individuals including portfolio managers, traders and others.
• The policy is appropriately disclosed in the firm's Form ADV.
• John Riley periodically monitors the firm's advisory services and trading practices to help ensure that no
agency cross transactions occur for advisory clients.
• In the event of any change in the firm's policy, any such change must be approved by management, any
agency cross transactions would only be allowed after appropriate authorizations, reviews, approvals,
disclosures, reporting and meeting appropriate regulatory requirements and maintaining proper records.