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Wrap Fee Adviser

Policy
CIS acts as an adviser in a wrap fee program.

Background
A wrap fee program is defined as any program under which any client is charged a specified fee or fees not based
directly upon transactions in a client’s account for investment advisory services (which may include portfolio
management or advice concerning the selection of other investment advisers) and execution of client transactions.
Wrap fee programs also typically include custody services as part of the all-inclusive services in the program.

Responsibility
John Riley has the responsibility for insuring the firm's policy is followed and that CIS’s s participation as an adviser
of a wrap fee program is approved and follows all regulatory requirements. .

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's designated officer monitors the firm's businesses and advisory services, including periodic reviews of
the firm's Form ADV and disclosures.
• CIS's designated officer also monitors the firm's advisory services to ensure that participation in any wrap
fee programs as an adviser/sub-adviser would only be allowed after appropriate management approvals,
disclosures and meeting regulatory requirements.