Common use of Identity Theft Prevention Program Clause in Contracts

Identity Theft Prevention Program. (a) The Trust delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES") in connection with the Trust's Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, the Trust AML Program, Atlantic Identity Theft Policies and Procedures, or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic to, and Atlantic acknowledges that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust hereby appoints Atlantic TA as its agent and delegates to AtlanticAtlantic TA as its agent, certain responsibilities required of the Trust under Regulation S-ID promulgated by the SEC that require the Trust to establish a program reasonably designed to detect, prevent and Atlantic hereby accepts, responsibility mitigate identity theft with respect to perform certain services the Trust shareholders (the "IDENTITY THEFT PREVENTION SERVICESTrust Identity Theft Prevention Program"). Atlantic TA hereby accepts such appointment and delegation. (b) In connection with such appointment, Atlantic TA hereby represents and warrants to the Trust that it: (i) has adopted and implemented written policies and procedures ("Identity Theft Policies and Procedures") in connection reasonably designed to comply with the requirements of Regulation S-ID that have been delegated to it by the Trust and to which Atlantic TA is otherwise subject; (ii) will provide prompt written notification to the Trust's Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program Compliance Officer ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURESITPCO") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic TA reasonably believes, based on the Trust's Identity Theft Prevention ProceduresProgram, evidence money laundering or identity theft activities in connection with the Trust or any shareholder Shareholder of the Trust; (iiiii) will provide prompt written notification to the ITPCO of any customer(s) account that Atlantic TA reasonably believesbelieves may be the subject of, based upon the Identity Theft Prevention Proceduresor involved in, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iiiiv) Any will provide immediate notification to the ITPCO of any activities, transactions or red flags that Atlantic TA, in its discretion, believes could indicate identity theft activities and will follow the directions of the ITPCO, CCO, AMLCO or Board of Trustees with respect to the monitoring or reporting of such activities, transactions or red flags; (v) will provide promptly to the ITPCO any reports received by Atlantic TA from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, authority having jurisdiction over the Trust AML Program, or Atlantic Identity Theft Policies and Procedures, or TA that relates to the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic to, and Atlantic acknowledges that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust hereby delegates to Atlanticthe Administrator, and Atlantic the Administrator hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES"“Identity Theft Prevention Services”) in connection with the Trust's ’s Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"“Trust Identity Theft Prevention Program”), as further set out in the Trust Identity Theft Prevention Program. Atlantic The Administrator further agrees to cooperate with the CCO Trust’s Chief Compliance Officer in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic The Administrator represents and warrants that: (i) Atlantic The Administrator undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic The Administrator has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES"“Administrator Identity Theft Prevention Program”) that includes policies and procedures that enable it to perform its responsibilities under this the Agreement, as amended hereby. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic the Administrator any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic The Administrator agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic the Administrator believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic the Administrator reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall agrees not to communicate this information to the customer; (iii) Any reports received by Atlantic the Administrator from any government agency or applicable industry self-regulatory organization pertaining to Atlantic the Administrator AML Policies and ProceduresProgram, the Trust AML Program, Atlantic the Administrator Identity Theft Policies and ProceduresPrevention Program, or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (i), (ii) ii or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic tohereby directs, and Atlantic acknowledges the Administrator acknowledges, that it the Administrator shall (i) permit federal regulators access to such information and records maintained by Atlantic the Administrator and relating to Atlantic's the Administrator’s implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's the Administrator’s implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES") in connection with the Trust's Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURESPREVENTION PROGRAM") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and ProceduresProgram, the Trust AML Program, Atlantic Identity Theft Policies and ProceduresPrevention Program, or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic to, and Atlantic acknowledges that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust hereby delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES"“Identity Theft Prevention Services”) in connection with the Trust's ’s Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"“Trust Identity Theft Prevention Program”), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES"“Atlantic Identity Theft Prevention Program”) that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the this Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and ProceduresProgram, the Trust AML Program, Atlantic Identity Theft Policies and ProceduresPrevention Program, or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust hereby directs Atlantic to, and Atlantic acknowledges acknowledges, that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's ’s implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's ’s implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust Fund hereby delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES"“Identity Theft Prevention Services”) in connection with the Trust's Fund’s Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"“Fund Identity Theft Prevention Program”), as further set out in the Trust Fund Identity Theft Prevention Program. Atlantic further agrees to cooperate with the CCO Fund’s Chief Compliance Officer in the performance of the Identity Theft Prevention Services as set forth in the Trust Fund Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Fund Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES"“Atlantic Identity Theft Prevention Program”) that includes policies and procedures that enable it to perform its responsibilities under this the Agreement, as amended hereby. (c) The Trust Fund represents and warrants that the Trust Fund will promptly provide Atlantic any amendment(s) to the Trust Fund Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust Fund with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder unitholder of the TrustFund; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall Fund agrees not to communicate this information to the customer; (iii) Any any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to the Atlantic AML Policies and Procedures, the Trust AML Program, the Fund AML Program, the Atlantic Identity Theft Policies and ProceduresPrevention Program, or the Trust Fund Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (i), (ii) ii or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustFund. (e) The Trust directs Atlantic toFund hereby directs, and Atlantic acknowledges acknowledges, that it Atlantic shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's ’s implementation of the Identity Theft Prevention Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect Atlantic's ’s implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c)Fund.

Identity Theft Prevention Program. (a) The Trust delegates and the CFC hereby delegate to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICESIdentity Theft Prevention Services") in connection with the Trust's and the CFC's respective Identity Theft Prevention Programs, as applicable (together, the "Trust Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURESAtlantic Identity Theft Prevention Program") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants the CFC represent and warrant that the Trust and/or the CFC, as applicable, will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the this Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust or the CFC, as applicable, with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust or the CFC or any shareholder of the TrustTrust or the CFC; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and ProceduresProgram, the Trust AML Program, Atlantic Identity Theft Policies and ProceduresPrevention Program, or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Each of the Trust directs and the CFC hereby direct Atlantic to, and Atlantic acknowledges acknowledges, that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's implementation of the Identity Theft Prevention Procedures, on behalf of the Trust/CFC, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust Fund hereby appoints Atlantic TA as its agent and delegates to AtlanticAtlantic TA as its agent, certain responsibilities required of the Fund under Regulation S-ID promulgated by the SEC that require the Fund to establish a program reasonably designed to detect, prevent and Atlantic hereby accepts, responsibility mitigate identity theft with respect to perform certain services the Fund Shareholders (the "IDENTITY THEFT PREVENTION SERVICES") in connection with the Trust's Fund Identity Theft Prevention TheftPrevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention ProgramTA hereby accepts such appointment and delegation. (b) In connection with such appointment, Atlantic TA hereby represents and warrants thatto the Fund that it: (i) has adopted and implemented written policies and procedures ("Identity TheftPolicies and Procedures") reasonably designed to comply with the requirements of Regulation S-ID that have been delegated to it by the Fund and to which Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; andTA is otherwise subject; (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust with the following: (i) prompt written notification to the Fund's Identity Theft Compliance Officer ("ITPCO") of any transaction or combination of transactions that Atlantic TA reasonably believes, based on the Fund's Identity Theft Prevention ProceduresProgram, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder Shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customerFund; (iii) Any reports received by will provide prompt written notification to the ITPCO of any account that Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, TA reasonably believes may be the Trust AML Program, Atlantic Identity Theft Policies and Proceduressubject of, or the Trust Identity Theft Prevention Programinvolved in, identity theft activities; (iv) prompt written will provide immediate notification to the ITPCO of any action taken activities, transactions or red flags that Atlantic TA, in response to its discretion, believes could indicate identity theft activity as described in (i)activities and will follow the directions of the ITPCO, (ii) CCO, AMLCO or (iii)the Board with respect to the monitoring or reporting of such activities, transactions or red flags; and (v) certified annual and quarterly will provide promptly to the ITPCO any reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic to, and Atlantic acknowledges that it shall (i) permit federal regulators access to such information and records maintained received by Atlantic and relating TA from any regulatory authority having jurisdiction over the Fund or Atlantic TA that relates to Atlantic's implementation of the Fund Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c)Program.

Identity Theft Prevention Program. (a) The Trust Fund hereby delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES"“Identity Theft Prevention Services”) in connection with the Trust's Fund’s Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"“Fund Identity Theft Prevention Program”), as further set out in the Trust Fund Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Fund Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Fund Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES"“Atlantic Identity Theft Prevention Program”) that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust Fund represents and warrants that the Trust Fund will promptly provide Atlantic any amendment(s) to the Trust Fund Identity Theft Prevention Program, which will be subject to the terms of the this Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust Fund with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of investor in the TrustFund; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, the Trust AML Program, Atlantic Identity Theft Policies and ProceduresPrevention Program, or the Trust Fund Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustFund. (e) The Trust Fund hereby directs Atlantic to, and Atlantic acknowledges acknowledges, that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's ’s implementation of the Identity Theft Prevention Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect Atlantic's ’s implementation of the Identity Theft Prevention Procedures on behalf of the TrustFund; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust delegates to AtlanticAtlantic TA, and Atlantic TA hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES"“Identity Theft Prevention Services”) in connection with the Trust's ’s Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"“Trust Identity Theft Prevention Program”), as further set out in the Trust Identity Theft Prevention Program. Atlantic TA agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic TA represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES"“Atlantic Identity Theft Prevention Procedures”) that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic TA any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic TA agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic TA believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic TA reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, the Trust AML Program, Atlantic the Identity Theft Policies and Procedures, Prevention Procedures or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic TA to, and Atlantic TA acknowledges that it shall (i) permit federal regulators access to such information and records maintained by Atlantic TA and relating to Atlantic's Atlantic TA’s implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's Atlantic TA’s implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(cSECTION 4(c).

Identity Theft Prevention Program. (a) The Trust hereby appoints Atlantic TA as its agent and delegates to AtlanticAtlantic TA as its agent, certain responsibilities required of the Trust under Regulation S-ID promulgated by the SEC that require the Trust to establish a program reasonably designed to detect, prevent and Atlantic hereby accepts, responsibility mitigate identity theft with respect to perform certain services the Trust shareholders (the "IDENTITY THEFT PREVENTION SERVICESTrust Identity Theft Prevention Program"). Atlantic TA hereby accepts such appointment and delegation. (b) In connection with such appointment, Atlantic TA hereby represents and warrants to the Trust that it: (i) has adopted and implemented written policies and procedures ("Identity Theft Policies and Procedures") in connection reasonably designed to comply with the requirements of Regulation S-ID that have been delegated to it by the Trust and to which Atlantic TA is otherwise subject; (ii) will provide prompt written notification to the Trust's Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program Compliance Officer ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURESITPCO") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic TA reasonably believes, based on the Trust's Identity Theft Prevention ProceduresProgram, evidence money laundering or identity theft activities in connection with the Trust or any shareholder Shareholder of the Trust; (iiiii) will provide prompt written notification to the ITPCO of any customer(s) account that Atlantic TA reasonably believesbelieves may be the subject of, based upon the Identity Theft Prevention Proceduresor involved in, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iiiiv) Any will provide immediate notification to the ITPCO of any activities, transactions or red flags that Atlantic TA, in its discretion, believes could indicate identity theft activities and will follow the directions of the ITPCO, CCO, AMLCO or Board of Trustees with respect to the monitoring or reporting of such activities, transactions or red flags; and (v) will provide promptly to the ITPCO any reports received by Atlantic TA from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, authority having jurisdiction over the Trust AML Program, or Atlantic Identity Theft Policies and Procedures, or TA that relates to the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic to, and Atlantic acknowledges that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's implementation of the Identity Theft Prevention Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES"“Identity Theft Prevention Services”) in connection with the Trust's ’s Red Flags Program or Identity Theft Prevention Program, (the "TRUST IDENTITY THEFT PREVENTION PROGRAM"“Trust Identity Theft Prevention Program”), as further set out in the Trust Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURES") that includes policies and procedures (“Atlantic Identity Theft Policies and Procedures”) that enable it to perform its responsibilities under this Agreement. (c) The Trust represents and warrants that the Trust will promptly provide Atlantic any amendment(s) to the Trust Identity Theft Prevention Program, which will be subject to the terms of the Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust or GCCM with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Atlantic Identity Theft Prevention Policies and Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Atlantic Identity Theft Prevention Policies and Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, the Trust AML Program, Atlantic Identity Theft Policies and Procedures, or the Trust Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. (e) The Trust directs Atlantic to, and Atlantic acknowledges that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's ’s implementation of the Atlantic Identity Theft Prevention Policies and Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect Atlantic's ’s implementation of the Atlantic Identity Theft Prevention Policies and Procedures on behalf of the Trust; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).

Identity Theft Prevention Program. (a) The Trust Fund hereby delegates to Atlantic, and Atlantic hereby accepts, responsibility to perform certain services (the "IDENTITY THEFT PREVENTION SERVICES") in connection with the TrustFund's Identity Theft Prevention Program, (the "TRUST FUND IDENTITY THEFT PREVENTION PROGRAM"), as further set out in the Trust Fund Identity Theft Prevention Program. Atlantic agrees to cooperate with the CCO in the performance of the Identity Theft Prevention Services as set forth in the Trust Fund Identity Theft Prevention Program. (b) Atlantic represents and warrants that: (i) Atlantic undertakes to perform all delegated responsibilities under the Trust Fund Identity Theft Prevention Program; and (ii) Atlantic has adopted and will maintain a written identity theft prevention program ("ATLANTIC IDENTITY THEFT POLICIES AND PROCEDURESPREVENTION PROGRAM") that includes policies and procedures that enable it to perform its responsibilities under this Agreement. (c) The Trust Fund represents and warrants that the Trust Fund will promptly provide Atlantic any amendment(s) to the Trust Fund Identity Theft Prevention Program, which will be subject to the terms of the this Agreement, as amended hereby. (d) Atlantic agrees to furnish the Trust Fund with the following: (i) prompt written notification of any transaction or combination of transactions that Atlantic believes, based on the Identity Theft Prevention Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of investor in the TrustFund; (ii) prompt written notification of any customer(s) that Atlantic reasonably believes, based upon the Identity Theft Prevention Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund shall not to communicate this information to the customer; (iii) Any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to Atlantic AML Policies and Procedures, the Trust AML Program, Atlantic Identity Theft Policies and ProceduresPrevention Program, or the Trust Fund Identity Theft Prevention Program; (iv) prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (i), (ii) or (iii); and (v) certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustFund. (e) The Trust Fund hereby directs Atlantic to, and Atlantic acknowledges acknowledges, that it shall (i) permit federal regulators access to such information and records maintained by Atlantic and relating to Atlantic's implementation of the Identity Theft Prevention Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect Atlantic's implementation of the Identity Theft Prevention Procedures on behalf of the TrustFund; any such provision of access or inspection shall be deemed outside of routine and normal periodic reviews as contemplated under Section 5(c).