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CIS P&P Addendum
Risk Assessment Questions
Below are questions from the RIA in a Box Risk Assessment. Not all questions are listed because some were
directly answered by the CIS ADV or P&P. Below are answers CIS felt were answered by the ADV and P&P, but CIS
wanted to expand upon the answers.
Marketing/Performance
5. Misrepresentation of Services Offered
Our policy on misrepresentation of services offered would be first to not do it and second, if we
discover it has been done, to correct it as soon as possible.
7. Misrepresentation about advisory firm and principals
Our policy on misrepresentations about the advisory firm and principals would be first to make
sure all information in our documents is correct and second, if we discover an error, to correct it as soon as
possible.
8, Use of past recommendations without following rules
Our policy on use of past recommendations is to not use past recommendation. If we discover
someone has used past recommendations, we will have them stop and any materials that may have been used
destroyed.
9. Inappropriate use of charts and graphs without proper disclosures
Our policy on charts and graphs is that they must have source disclosures. If we discover any
charts and graphs without proper disclosures, our policy is to immediately add the proper disclosures.
Form ADV/Disclosures
15. Inaccurate, omitted, or unclear disclosures
Our policy is to have clear, accurate and understandable disclosures. If we discover that a
disclosure is inaccurate, or unclear, we will change it to correct the inaccuracy or make it more understandable as
soon as the error is discovered.
16. Misrepresentation of services offered
Our policy on misrepresentation of services offered would be first to not misrepresent our
services offered and second, if we discover it has been done, to correct it as soon as possible.
18. Overstating regulatory assets under management (AUM)
Our policy is to accurately state our regulatory assets under management. If we discover there
has been an error, then we will correct it as soon as it is discovered, updating the proper documents.
19. Timely filing of other required Forms (i.e. 13F, 13D, 13G, 13H)
Our policy is to file all documents in a timely manner, and if it is discovered that we have not, to
file as soon as possible.
20. Accuracy of other regulatory filings (13F, etc...)
Our policy is that all regulatory filings are accurate. If we discover any errors, we will have them
corrected as soon as possible.
Invoices/Fees/Valuations
21. Non-"research" products obtained without disclosure
Our policy is to disclose any non- research products we obtain. If we discover that a product has
been obtained without disclosure, we will correct it as soon as possible.