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This program shall be updated periodically to reflect changes in risks to customers of the Commission from identity theft based on factors such as:

(a) The experiences of the Commission with identity theft;

(b) Changes in methods of identity theft;

(c) Changes in methods to detect, prevent and mitigate identity theft;

(d) Changes in the types of accounts that the Commission offers or maintains;

(e) Changes in the business arrangements of the Commission including mergers, acquisitions, alliances, joint ventures and service provider arrangements; or

(f) Changes in laws that may impose new requirements or limitations on established policies. (GMO 09-01 § V)