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Supervision & Internal Controls
Form ADV (Part 2A and 2B) & Update Procedures

Policy
CIS, as a matter of policy, complies with relevant regulatory requirements and maintains our Disclosure Document
on a current and accurate basis. Our firm's Disclosure Document provides information about the firm’s advisory
services, business practices, professionals, policies and any actual and potential conflicts of interest, custodial and
brokerage relationships .

Background
As a registered investment adviser, CIS has a duty to comply with the disclosure document delivery requirements
of Rule 204-3(a) under the Advisers Act, or similar state regulations. An adviser's Disclosure Document may be
Form ADV Part 2 or a wrap fee brochure, or another document containing all of the information required by Form
ADV Part 2.

Responsibility
John Riley has the responsibility for maintaining CIS's Disclosure Document on a current and accurate basis, making
appropriate amendments and filings, ensuring initial delivery of the Disclosure Document to new clients, sending
the annual client offer of the Disclosure Document and maintaining all appropriate files.

ADV PART 2A Firm Brochure
CIS must update the brochure: (a) each year at the time CIS files the annual updating amendment; and (b)
promptly whenever any information in the brochure becomes materially inaccurate. CIS is not required to update
the brochure between annual amendments solely because the amount of client assets managed has changed or
because the fee schedule has changed. However, if CIS is updating the brochure for a separate reason in between
annual amendments, and the amount of client assets managed listed or the fee schedule listed has become
materially inaccurate, CIS will update that/those item(s) as part of the interim amendment. All updates to the
brochure must be filed through the IARD system and maintained in our files.
• If CIS is filing the annual updating amendment and the last brochure that was filed does not contain any
materially inaccurate information CIS does NOT have to prepare a summary of material changes. (This
assumes CIS has not filed any interim amendments making material changes to the brochure that was
filed with last year’s annual updating amendment.) If CIS does not have to prepare a summary of material
changes, CIS does not have to deliver a summary of material changes or a brochure to existing clients that
year. (However, it is considered a “Best Practice” – especially for firms who deliver this document
electronically – for each firm to just include a complete ADV 2A document (along with the required annual
Privacy Policy Statement delivery) each year to every client before the deadline stated above.)
• CIS may include a summary of the brochure at the beginning of your brochure.
• CIS may prepare multiple firm brochures. If CIS offers substantially different types of advisory services, CIS
may opt to prepare separate brochures so long as each client receives all applicable information about
services and fees. Each brochure may omit information that does not apply to the advisory services and
fees it describes. For example, the firm brochure sent to clients who invest only in the United States can
omit information about advisory services and fees relating to offshore investments. If CIS prepares
separate brochures CIS must file each brochure (and any amendments) through the IARD system.
• If CIS sponsors a wrap fee program, there is a different brochure that CIS needs to deliver to wrap fee
clients. CIS must deliver a Wrap Fee Program Brochure to wrap fee clients. The disclosure requirements
for preparing this brochure appear in Part 2A, Appendix 1 of Form ADV. If the entire advisory business is
sponsoring wrap fee programs, CIS does not need to prepare a firm brochure (ADV 2A) separate from the
wrap fee program brochure(s).
• If CIS provides portfolio management services to clients in wrap fee programs that CIS does not sponsor,
CIS must deliver the brochure prepared in accordance with Part 2A (not Appendix 1) to wrap fee clients.

CIS also must deliver to these clients any brochure supplements required by Part 2B of Form ADV.