Atwal had two birdies and two bogeys on the front nine after cards of 73 and 71 on first two days.
Also tied at 37th was Daniel Chopra, who shot 73 on the third day.
Both Atwal and Chopra, both of whom don't have the Tour card for this season, are playing their first event on the PGA Tour in 2015 and have been playing more on the Asian Tour.
Brown, who won the Puerto Rico Open two years ago, birdied the final two holes for a 67 at Trump International-Puerto Rico.
They were at six-under 2010.
Smith last had a full PGA TOUR card in 2005 and was playing on the Web.Com Tour when his wife was killed.
Rookie Jon Curran and Argentina's Emiliano Grillo were a stroke back. Curran had a 70, and Grillo shot 72. Second-round leader Alex Cejka dropped four strokes on the final four holes to fall into a tie for fifth at 4 under 212.
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