Updated: May 1, 2008

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 Our 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.

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Executive Lending Services, Inc. - 13873 Park Center Road, Suite 136 - Herndon, VA 20171
Office Phone: (703) 691-0958 Fax: (703) 991-8687

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We are licensed to lend in Virginia.

Licensed by: Virginia State Corporation Commission

License Number: MB-3095

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