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22. Fair value method used for difficult assets (need a policy)
Our policy on fair value method used for difficult assets is to make a best efforts attempt at
valuing the assets. If we find that the valuation is substantially off, then we will correct it as soon as possible.

29. Rebating of fees
Our policy is to not rebate fees. If we discover this is happening, we will end the practice and
may terminate the employee.

Some standard benefits of using Schwab as our custodian which are not exclusive to CIS:
Charles Schwab & Co., Inc. Advisor Services provides CIS with access to Charles Schwab & Co., Inc. Advisor Services’
institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor
Services retail investors. These services generally are available to independent investment advisers on an
unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are
maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services
includes brokerage services that are related to the execution of securities transactions, custody, research,
including that in the form of advice, analyses and reports, and access to mutual funds and other investments that
are otherwise generally available only to institutional investors or would require a significantly higher minimum
initial investment. For CIS client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services
generally does not charge separately for custody services but is compensated by account holders through
commissions or other transaction-related or asset-based fees for securities trades that are executed through
Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts

IPO Offerings
31. Directing trades to brokers that provide IPO offerings
Our policy is to not be involved with IPOs. Since this is the case, we need no policy for direct
trades to IPO issuers.

33. Not allocating IPO's across clients fairly
Our policy is to not be involved with IPOs. Since this is the case, we need no policy for allocating
IPO’s.

Compensation
44. Incentive-based compensation leads to inappropriate recommendations
Our money management compensation is based on fees, so there is no incentive base to
recommend one security over another. Since our IARs are not also registered reps of a BD, they have no conflict
with commission based products.

45. Double dipping or any other form of compensation being generated without being fully disclosed
Our money management compensation is based on fees, so there is no incentive base to
recommend one security over another. Our IAR’s are not registered reps of a BD, so this does not present the
potential for a conflict of interest.

46. Charging performance fees not in accordance with statute
CIS does not charge performance fees, so there is no need to have a policy regarding
performance fees, other than we do not charge them.

47. Unfair or undisclosed performance fees
CIS does not charge performance fees, so there is no need to have a policy regarding
performance fees, other than we do not charge them.

Objectives/Restrictions/Suitability
48. Not collecting suitability information (financial condition, objectives, risk etc..)
Our policy is to collect suitability information on all clients. If we discover we have not collected
the proper information on a client, our policy is to collect the information as soon as possible.