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Procedure
CIS has adopted various procedures to implement the firm’s policy and reviews to monitor and ensure the firm’s
disclosure document policy is observed, implemented properly and amended or updated, as appropriate, which
include the following:

1. Initial Delivery
• A representative of CIS will provide a copy of the firm’s current Disclosure Document, which may include a
wrap fee brochure, to each prospective client either: at the time of entering into an advisory agreement
with a client; or, not less than 48 hours prior to entering into an advisory agreement with a client. The IAR
ADV 2B brochure will be delivered to the client prior to contracting with CIS.
• CIS will maintain a document or acknowledgement evidencing delivery of the Disclosure Document to
each client.
• The Compliance Officer will maintain dated copies of all CIS's complete Disclosure Documents so as to be
able to identify which Disclosure Document was in use at any time.

2. Annual Offer/Delivery
CIS will provide annually a copy of the ADV 2A to all current advisory clients.
CIS will maintain an “Annual Offer File” for each calendar year which will include:
1. a sample copy of the Annual Offer,
2. a copy of the Disclosure Document offered to clients for the particular year,
3. a list of the names and addresses of the clients to whom CIS sent a
Form ADV 2A,
4. copies of CIS's letters to clients sending the Disclosure Document.

3. Review and Amendment
• The designated officer will review the firm’s complete Disclosure Document on a periodic basis to
maintain the Disclosure Document on a current and accurate basis and to properly reflect and be
consistent with the firm’s current services, business practices, fees, investment professionals, affiliations
and conflicts of interest, among other things.
• When changes or updates to the Disclosure Document are necessary or appropriate, the designated
officer will make any and all disclosure document amendments timely and promptly and maintain records
of the filings and amendments.

ADV PART 2B Firm Brochure Supplement
• CIS must update brochure supplements promptly whenever any information in them becomes materially
inaccurate.
• CIS may deliver supplements electronically. If CIS delivers a supplement electronically, CIS may disclose
in that supplement that the supervised person has a disciplinary event and provide a hyperlink to either
the BrokerCheck (www.finra.org/Investors/ToolsCalculators/BrokerCheck) or the IAPD
(www.adviserinfo.sec.gov) systems.

• If CIS is registered or is registering with one or more state securities authorities, CIS must file through
IARD a copy of the brochure supplement for each supervised person doing business in that state.

ADV Update Requirements
The firm’s Chief Compliance Officer (CCO) shall review, at least annually, the firm’s ADV Form and all related
documents. The CCO shall file amendments to Part 1A of the Form ADV electronically with the Investment Adviser
Registration Depository (IARD) within 90 days of the firm’s fiscal year end. Material changes to Part 2A & 2B shall
be made promptly (at least within 30 days) and the updated brochure shall be delivered to all prospective clients
and offered to clients on an annual basis.

The CCO shall see that a current copy of the Form ADV (2A & 2B) is kept on file, as well as a copy of all old Form
ADV’s.