Common use of Customer Identification Program; FinCEN Requests Clause in Contracts

Customer Identification Program; FinCEN Requests. (a) To help the government fight the funding of terrorism and money laundering activities, federal law requires each financial institution to obtain, verify and record information that identifies each person who opens an account with that financial institution. Consistent with this requirement, ALPS will request each party’s name, address, taxpayer identification number or other government-issued identification number, and if such party is a natural person, that party’s date of birth. ALPS may also ask for additional identifying information, and ALPS may take steps to verify the authenticity and accuracy of these data elements. (b) ALPS will compare account information to any Financial Crimes Enforcement Network (“FinCEN”) request provided to ALPS pursuant to USA Patriot Act Section 314(a) by the Fund or by ALPS Distributors, Inc. (“ADI”), if ADI serves as the Fund’s distributor, and will provide the Fund with the necessary information for it to respond to such FinCEN request within the required time frame.

Customer Identification Program; FinCEN Requests. (a) To help the government fight the funding of terrorism and money laundering activities, federal Federal law requires each financial institution to obtain, verify and record information that identifies each person who opens an account with that financial institution. Consistent with this requirement, ALPS will do all things necessary to comply with all applicable laws and regulations, including request each party’s name, address, taxpayer identification number or other government-issued identification number, and if such party is a natural person, that party’s date of birth. ALPS may also ask for additional identifying information, and ALPS may take steps to verify the authenticity and accuracy of these data elements. (b) ALPS will compare account information to any Financial Crimes Enforcement Network (“FinCEN”) request provided to ALPS pursuant to USA Patriot Act Section 314(a) by the Fund or by ALPS Distributors, Inc. (“ADI”), if ADI serves as the Fund’s distributor, and will provide the Fund with the necessary information for it to respond to such FinCEN request within the required time frame.