Executive Lending Services, Inc.| Information Security Policy

Info. Security Policy

Updated: May 1, 2009

Executive Lending Services, Inc.
13873 Park Center Road, Suite 136
Herndon, VA 20171

Information Security Policy as required by:Grahamm-Leach-Bliley Act

Information Security Program Officer: John L. Carter, President

Identification of Reasonably Foreseeable Threats:

*Threat*	Internet Hacker Logging Into Server
*Safeguard*	Hardware & Software Firewalls And Separate Administrative & User Passwords To Be Changed On A Quarterly Basis

*Threat*	Lost or Stolen Laptop / Compromised Passwords
*Safeguard*	Immediately Change Users Passwords

*Threat*	Unauthorized Access To Printed Personally Identifiable Financial Information (PIFI)
*Safeguard*	Immediately Shred & Discard Printed Document Immediately After Use / No Printed PIFI Is To Be Stored In Physical Format

*Threat*	Business To Business Sharing Of PIFI
*Safeguard*	Relevant Documents Are Imaged Into Out Loan Origination System And The Originals Are Destroyed

*Threat*	Administrative Protection Of PIFI
*Safeguard*	To Limit Potential Damage Done By Unauthorized Disclosure Of Client PIFI Individual Loan Officers Only Have Access To Their Personally Generated Data

*Threat*	Physical Safeguards To Client PIFI
*Safeguard*	All Exterior Doors Are Dead-bolted And Premises Are Secured By A Third Party Remotely Monitored Security System

The Information Security Program Officer will meet with ELS personnel periodically to review and implement the program. Based upon the information gathered by performing risk assessments, and as changes in laws or regulations require the ISPO will assess the need for and arrange for training of ELS personnel and will provide policy and procedure updates as may be necessary to ensure the program is properly implemented.

This document to be reviewed and updated annually or sooner as dictated by circumstances.