Common use of IMPARTIAL CONDUCT STANDARDS Clause in Contracts

IMPARTIAL CONDUCT STANDARDS. CIAS has determined that its fees are reasonable by industry standards, when taking into consideration the following services being provided: ongoing professional asset management; regular portfolio reviews; performance reporting, upon request; access to financial, income and estate planning services; direct and immediate access to account holdings and, operational and account support services. For complete details regarding potential conflicts of interest, please refer CIAS’s ADV Part 2A (Brochure). CIAS has developed policies and practices, including a Code of Ethics, to adhere to best practices and address potential conflicts of interest that may arise. IARs may also be Registered Representatives of Capital Investment Group, Inc. or Capital Investment Brokerage, Inc., affiliated broker‐dealers. In this capacity, an IAR may receive varying commission or remuneration, which may present a potential conflict of interest due to an incentive to recommend products based on additional compensation. There may also be financial incentives by the affiliated broker‐dealer to recommend the custodial services of Pershing LLC, due to their exclusive clearing arrangement, or use of specific investment company products, due to varying compensation received from such programs as revenue sharing or strategic partner programs.

IMPARTIAL CONDUCT STANDARDS. CIAS has determined that its fees are reasonable by industry standards, when taking into consideration the following services being provided: ongoing professional asset management; regular portfolio reviews; performance reporting, upon request; access to financial, income and estate planning services; direct and immediate access to account holdings and, operational and account support services. For complete details regarding potential conflicts of interest, please refer CIAS’s ADV Part 2A (Brochure). CIAS has developed policies and practices, including a Code of Ethics, to adhere to best practices and address potential conflicts of interest that may arise. IARs may also be Registered Representatives of Capital Investment Group, Inc. or Capital Investment Brokerage, Inc., affiliated broker‐dealersbroker-dealers. In this capacity, an IAR may receive varying commission or remuneration, which may present a potential conflict of interest due to an incentive to recommend products based on additional compensation. There may also be financial incentives by the affiliated broker‐dealer broker-dealer to recommend the custodial services of Pershing LLC, due to their exclusive clearing arrangement, or use of specific investment company products, due to varying compensation received from such programs as revenue sharing or strategic partner programs.