Common use of USBFS Red Flag Identity Theft Prevention Program Clause in Contracts

USBFS Red Flag Identity Theft Prevention Program. The Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company has determined that the Procedures, as part of the Company’s overall Identity Theft Prevention Program, are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this determination, the Company hereby instructs and directs USBFS to implement the Procedures on the Company’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Company’s identity theft responsibilities. USBFS agrees to supply the Identity Theft Prevention Officer for the Company. USBFS agrees to implement the Company’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying Red Flags that may be associated with identity theft based upon an ongoing risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; (3) methods to access accounts; (4) previous experience with identity theft; (5) current experience with identity theft; and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; (2) suspicious shareholder transactions; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; (5) supervisory review and quality assurance checks; and (6) fraud/AML software exception reports.

USBFS Red Flag Identity Theft Prevention Program. The Company Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company Trust has determined that the Procedures, as part of the CompanyTrust’s overall Identity Theft Prevention Program, are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this determination, the Company Trust hereby instructs and directs USBFS to implement the Procedures on the CompanyTrust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the CompanyTrust’s identity theft responsibilities. USBFS agrees to supply the Identity Theft Prevention Officer for the CompanyTrust. USBFS agrees to implement the CompanyTrust’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying Red Flags that may be associated with identity theft based upon an ongoing risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; (3) methods to access accounts; (4) previous experience with identity theft; (5) current experience with identity theft; and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; (2) suspicious shareholder transactions; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; (5) supervisory review and quality assurance checks; and (6) fraud/AML software exception reports.

USBFS Red Flag Identity Theft Prevention Program. The Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company has determined that the Procedures, as part of the Company’s overall Identity Theft Prevention Program, are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this determination, the Company hereby instructs and directs USBFS to implement the Procedures on the Company’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Company’s identity theft responsibilities. USBFS agrees to supply the Identity Theft Prevention Officer for the Company. USBFS agrees to implement the Company’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying Red Flags that may be associated with identity theft based upon an ongoing on-going risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; (3) methods to access accounts; (4) previous experience with identity theft; (5) current experience with identity theft; and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; (2) suspicious shareholder transactions; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; (5) supervisory review and quality assurance checks; and (6) fraud/AML software exception reports.

USBFS Red Flag Identity Theft Prevention Program. The Company acknowledges Trusts acknowledge that it has they have had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company has Trusts have determined that the Procedures, as part of the Company’s overall Trusts’ Identity Theft Prevention Program (the “Program”), are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this that determination, the Company Trusts hereby instructs instruct and directs direct USBFS to implement the Procedures on the Company’s Trusts’ behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Company’s Trusts’ identity theft responsibilities. USBFS agrees to supply the Identity Theft Prevention Officer for the Company. USBFS agrees to implement the Company’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying patterns, practices and specific forms of activity that indicate a possible risk of identity theft (“Red Flags Flags”) that may be associated with identity theft based upon an ongoing on-going risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; ; (3) methods to access accounts; ; (4) previous experience with identity theft; ; (5) current experience with identity theft; and and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; ; (2) suspicious shareholder transactions; ; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; ; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; ; (5) supervisory review and quality assurance checks; and and (6) fraud/AML software exception reports.

USBFS Red Flag Identity Theft Prevention Program. The Company Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company Trust has determined that the Procedures, as part of the CompanyTrust’s overall Identity Theft Prevention Program, are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this determination, the Company Trust hereby instructs and directs USBFS to implement the Procedures on the CompanyTrust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the CompanyTrust’s identity theft responsibilities. USBFS agrees to supply the Identity Theft Prevention Officer for the CompanyTrust. USBFS agrees to implement the CompanyTrust’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying Red Flags that may be associated with identity theft based upon an ongoing on-going risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; (3) methods to access accounts; (4) previous experience with identity theft; (5) current experience with identity theft; and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; (2) suspicious shareholder transactions; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; (5) supervisory review and quality assurance checks; and (6) fraud/AML software exception reports.

USBFS Red Flag Identity Theft Prevention Program. The Company Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which that are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company Trust has determined that the Procedures, as part of the CompanyTrust’s overall Red Flag Identity Theft Prevention Program, are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this determination, the Company Trust hereby instructs and directs USBFS to implement the Procedures on the CompanyTrust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the CompanyTrust’s identity theft responsibilities. USBFS agrees to supply implement the Trust’s Identity Theft Prevention Officer for the Company. USBFS agrees to implement the Company’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying Red Flags patterns, practices or specific activities that indicate the possible existence of fraud or attempted fraud that may be associated with identity theft (“Red Flags”) based upon an ongoing on-going risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; (3) methods to access accounts; (4) previous experience with identity theft; (5) current experience with identity theft; and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; (2) suspicious shareholder transactions; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; (5) supervisory review and quality assurance checks; and (6) fraud/AML software exception reports.

USBFS Red Flag Identity Theft Prevention Program. The Company Corporation acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which that are designed to promote the detection and reporting of identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Company Corporation has determined that the Procedures, as part of the CompanyCorporation’s overall Red Flag Identity Theft Prevention Program, are reasonably designed to prevent identity theft and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the implementing regulations thereunder. Based on this determination, the Company Corporation hereby instructs and directs USBFS to implement the Procedures on the CompanyCorporation’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the CompanyCorporation’s identity theft responsibilities. USBFS agrees to supply implement the Corporation’s Identity Theft Prevention Officer for the Company. USBFS agrees to implement the Company’s Identity Theft Program (the “Program”) and is responsible for the following: A. Identifying Red Flags patterns, practices or specific activities that indicate the possible existence of fraud or attempted fraud that may be associated with identity theft (“Red Flags”) based upon an ongoing on-going risk assessment that includes an analysis of various risk factors such as: (1) types of accounts; (2) methods to open accounts; (3) methods to access accounts; (4) previous experience with identity theft; (5) current experience with identity theft; and (6) anticipated experience with identity theft based upon information gathered from both inside and outside sources such as affiliates, law enforcement and industry meetings. B. Detecting Red Flags through the following sources: (1) suspicious shareholder documentation; (2) suspicious shareholder transactions; (3) inconsistent shareholder information resulting from Anti-Money Laundering/Customer Identification Program reviews; (4) inability to authenticate shareholder via telephone, internet or documentation requiring a signature guarantee; (5) supervisory review and quality assurance checks; and (6) fraud/AML software exception reports.