Identity Theft Prevention Program. The Transfer Agent shall implement policies and procedures and shall cause Boston Financial Data Services, Inc. (“BFDS”) or any successor to BFDS or any entity performing substantially similar services to implement policies and procedures to detect, prevent and mitigate identity theft in accordance with the Identity Theft Protection Program adopted by the Funds, as the same may be amended from time to time. Such policies and procedure shall include, inter alia, policies designed to detect, identify and respond to a pattern, practice, or specific activity that indicates the possible existence of identity theft (“Red Flags”).
Appears in 6 contracts
Samples: Transfer, Dividend Disbursing and Shareholders’ Servicing Agent Agreement (Columbia Acorn Trust), Transfer, Dividend Disbursing and Shareholders’ Servicing Agent Agreement (Columbia Acorn Trust), Transfer, Dividend Disbursing and Shareholders’ Servicing Agent Agreement (Wanger Advisors Trust)
