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Heightened Supervision

In addition to CIS’s standard supervisory procedures for IARs, certain IARs may be subject to heightened
supervision by CIS’s CCO. This increased supervision will vary on a case by case basis, and can be imposed
indefinitely or for a limited period of time. The CCO will determine the scope and length of heightened supervision
for any IAR, taking into account any heightened supervision required by regulatory bodies. CIS’s CCO may or may
not inform the IAR of the heightened supervision. The CCO may also designate other CIS personnel to implement
the heightened supervisory procedures.

Heightened supervisory procedures may include but are not limited to:
● Limitations on products or services that may be offered by the IAR
● Increased review of client accounts managed by the IAR
● Increased review of the IAR’s correspondence including email
● Increased IAR training or education requirements
● Increased IAR remote office visits (if applicable)

CIS’s CCO will maintain a list of all past and present IARs subject to heightened supervision, which list will include
at a minimum:
● The relevant details of why the IAR was placed under heightened supervision
● Duration of the heightened supervision
● Nature and frequency of the additional supervisory procedures implemented
● Name(s) of CIS personnel performing these heightened supervisory procedures
● Observations from the heightened supervision reviews performed by CIS

A copy of this list will be kept in the personnel file for any applicable IAR.