FinCEN Requests Under USA PATRIOT Act. Section 314(a). The Funds hereby engage DTI to provide the services set forth in this subsection (3)(b)(4) with respect to FinCEN Section 314(a) information requests ("Information Requests") received by a Fund. Upon receipt by DTI of an Information Request, including those delivered by a Fund in compliance with the 314(a) Procedures (as defined below), DTI will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the relevant Fund. Information relating to potential matches resulting from these comparisons, after review by DTI for quality assurance purposes ("Comparison Results"), will be made available to the Funds in a timely manner. DTI will have responsibility for filing reports with FinCEN that may be appropriate based on the Comparison Results. In addition, a potential match will be analyzed by DTI in conjunction with other relevant activity contained in records for the particular relevant account. If DTI determines that further investigation is warranted because the activity might constitute "suspicious activity", as that term is used for purposes of the USA PATRIOT Act, then DTI will deliver a suspicious activity referral to the Funds' AML Compliance Officer and will perform the services set forth in Section 3(b)(6)(C). "314(a) Procedures" means the DTI Procedures governing the delivery and processing of Information Requests transmitted to DTI, including without limitation requirements governing the timeliness, content, completeness, format and mode of transmissions to DTI.
FinCEN Requests Under USA PATRIOT Act. Section 314(a). BNYM will provide the services set forth in this Section 3(b)(4) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon receipt by BNYM of an Information Request delivered by the Fund in full compliance with all 314(a) Procedures (as defined below), BNYM will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the Fund. Information relating to potential matches resulting from these comparisons, after review by BNYM for quality assurance purposes (“Comparison Results”), will be made available to the Fund in a timely manner. In addition, a potential match will be analyzed by BNYM in conjunction with other relevant activity contained in records for the particular relevant account, and if, after such analysis, BNYM determines that further investigation is warranted because the activity might constitute “suspicious activity”, as that term is used for purposes of the USA PATRIOT Act, then BNYM will deliver a suspicious activity referral to the Fund. BNYM shall have no responsibility for filing reports with FinCEN that may be appropriate based on the Comparison Results or a referral. Such responsibility, as between the Fund and BNYM, shall remain with the Fund exclusively. “314(a) Procedures” means the procedures adopted from time to time by BNYM governing the delivery and processing of Information Requests transmitted by BNYM’s clients to BNYM, including without limitation requirements governing the timeliness, content, completeness, format and mode of transmissions to BNYM.
FinCEN Requests Under USA PATRIOT Act. Section 314(a). BNYM will provide the services set forth in this Section 3(b)(4) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon receipt by BNYM of an Information Request delivered by the Fund in full compliance with all 314(a) Procedures (as defined below), BNYM will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the Fund. Information relating to potential matches resulting from these comparisons, after review by BNYM for quality assurance purposes (“Comparison Results”), will be made available to the Fund in a timely manner. In addition, a potential match will be analyzed by BNYM in conjunction with other relevant activity contained in records for the particular relevant account, and if, after such analysis, BNYM determines that further investigation is warranted because the activity might constitute “suspicious activity”, as that term is used for purposes of the USA PATRIOT Act, then BNYM will deliver a suspicious activity referral to the Fund in a timely manner, with “timely” in this instance meaning the Fund will be Confidential And Proprietary Execution Version
FinCEN Requests Under USA PATRIOT Act. Section 314(a). The Fund hereby engages PNC to provide certain services as set forth in this Section 3(b)(4) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon receipt by PNC of an Information Request delivered by the Fund in full compliance with all 314(a) Procedures (as defined below), PNC will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the Fund pursuant to this Agreement. Information relating to potential matches resulting from these comparisons, after review by PNC for quality assurance purposes (“Comparison Results”), will be made available to the Fund in a timely manner. The Fund will retain responsibility for filing reports with FinCEN that may be appropriate based on the Comparison Results. In addition, (i) a potential match involving a tax identification number will be forwarded by PNC to PNC’s SAR Service for analysis in conjunction with other relevant activity contained in records for the particular relevant account, and (ii) if, after such analysis, PNC’s SAR Service determines that the potential match could constitute a “suspicious activity,” as that term is used for purposes of the USA Patriot Act, then PNC’s SAR Service will deliver a suspicious activity referral to the Fund. “314(a) Procedures” means the procedures adopted from time to time by PNC governing the delivery and processing of Information Requests transmitted by PNC’s clients to PNC, including without limitation requirements governing the timeliness, content, completeness, format and mode of transmissions to PNC.
FinCEN Requests Under USA PATRIOT Act. Section 314(a). The Fund hereby engages Co-Transfer Agent to provide the services as set forth in this subsection (2) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon receipt by Co-Transfer Agent of an Information Request delivered by the Fund in full compliance with all 314(a) Procedures (as defined below), Co-Transfer Agent will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the Fund. Co-Transfer Agent’s comparison will be limited to current accounts, accounts maintained by a named customer during the preceding 12 months, and transactions conducted by or on behalf of or with a named customer during the preceding six months. Information relating to potential matches resulting from these comparisons, after review by Co-Transfer Agent for quality assurance purposes (“Comparison Results”), will be made available to the Fund in a timely manner. The Fund will retain responsibility for filing reports with FinCEN that may be appropriate based on the Comparison Results. In addition, (i) a potential match involving a tax identification number will be forwarded by Co-Transfer Agent to Co-Transfer Agent’s SAR Filing Service for analysis in conjunction with other relevant activity contained in records for the particular relevant account, and (ii) if, after such analysis, the Fund’s AML Officer and Co-Transfer Agent jointly determine that the potential match could constitute a “suspicious activity”, as that term is used for purposes of the USA Patriot Act, then Co-Transfer Agent’s SAR Filing Service will prepare and file a SAR. “314(a) Procedures” means the procedures adopted from time to time by PNC governing the delivery and processing of Information Requests transmitted by PNC’s clients to PNC, including without limitation requirements governing the timeliness, content, completeness, format and mode of transmissions to PNC. In accordance with applicable law, Co-Transfer Agent shall not disclose to any other person, other than FinCEN or the federal law enforcement agency on whose behalf FinCEN has requested or obtained information, the fact that FinCEN has requested or obtained information pursuant to an Information Request, except to the extent necessary to comply with such Information Request. Co-Transfer Agent agrees to comply with procedures mutually agreed upon by the parties and in compliance with applicab...
FinCEN Requests Under USA PATRIOT Act. Section 314(a). Each GE Party hereby engages USBFS to provide certain services as set forth herein with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the GE Parties. Upon receipt by USBFS of an Information Request delivered by a GE Party in full compliance with all 314(a) Procedures (as defined below), USBFS will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the GE Parties. Information relating to potential matches resulting from these comparisons, after review by USBFS for quality assurance purposes (“Comparison Results”), will be made available to the GE Parties in a timely manner. Each GE Party will retain responsibility for filing reports with FinCEN that may be appropriate based on the Comparison Results. In addition, (i) a potential match involving a tax identification number will be forwarded by USBFS to USBFS’ SAR Filing Service for analysis in conjunction with other activity contained in records for the particular Relevant Account, and (ii) if, after such analysis, a GE Party’s AML Compliance Officer and USBFS jointly determine that the potential match could constitute a “suspicious activity”, as that term is used for purposes of the USA Patriot Act, then USBFS’ SAR Filing Service will prepare and file a SAR. “314(a) Procedures” means the procedures adopted from time to time by USBFS governing the delivery and processing of Information Requests transmitted by USBFS’ clients to USBFS, including without limitation requirements governing the timeliness, content, completeness, format and mode of transmissions to USBFS.
FinCEN Requests Under USA PATRIOT Act. Section 314(a). The Fund hereby engages BNYM to provide certain services as set forth in this subsection (b) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon
FinCEN Requests Under USA PATRIOT Act. Section Section 314(a). The Fund hereby engages PFPC to undertake reviews, in response to FinCEN Section 314(a) Information Requests received by the Fund and transmitted to PFPC, of the Fund’s records of accounts and transactions that PFPC maintains on behalf of the Fund. The Fund recognizes that it is responsible under applicable regulations for responding to Section 314(a) Information Requests. Nonetheless, unless otherwise instructed by the Fund, PFPC will conduct a search pursuant to the Section 314(a) request which will be limited to current accounts, accounts maintained by a named customer during the preceding 12 months, and transactions conducted by or on behalf of or with a named customer during the preceding six months. When a potential FinCEN Section 314(a) Information Request match (first and last name or tax identification number) results from PFPC’s established Section 314(a) review procedures, the match will be referred to the Fund for reporting to FinCEN, as the Fund may determine to be appropriate. In addition, for accounts where both the name and social security number match, the match will be reviewed according to PFPC’s established CIP exception processing procedures. If the account match is confirmed using these CIP exception processing procedures, the account activity will be reviewed and, if PFPC in coordination with the Fund’s AML Compliance Officer, determines the account and/or activity is suspicious, the item will be referred to PFPC’s SAR Filing Service process for further analysis, and if appropriate, for preparation and filing of a SAR. PFPC will be obligated hereunder to undertake reviews relating to FinCEN Section 314(a) Information Requests, notifying the Fund of potential FinCEN Section 314(a) Information Request matches and reporting related suspicious activity on Form SAR only to the extent the FinCEN Section 314(a) Information Request is timely provided to PFPC by the Fund.
FinCEN Requests Under USA PATRIOT Act. Section 314(a). The Fund hereby engages BNYM to provide certain services as set forth in this subsection (b) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon receipt by BNYM of an Information Request delivered by the Fund in full compliance with all 314(a) Procedures (as defined below), BNYM will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the Fund. Information relating to potential matches resulting from these comparisons, after review by BNYM for quality assurance purposes (“Comparison Results”), will be made available to the Fund in a timely manner. The Fund will retain responsibility for filing reports
FinCEN Requests Under USA PATRIOT Act. Section 314(a). The Fund hereby engages PNC to provide certain services as set forth in this subsection (b) with respect to FinCEN Section 314(a) information requests (“Information Requests”) received by the Fund. Upon receipt by PNC of an Information Request delivered by the Fund in full compliance with all 314(a) Procedures (as defined below), PNC will compare appropriate information contained in the Information Request against relevant information contained in account records maintained for the Fund. Information relating to potential matches resulting from these comparisons, after review by PNC for quality assurance purposes (“Comparison Results”), will be made available to the Fund in a timely manner. The Fund will retain
