Regarding the FTC Safeguarding Customer Information Policy

Student information submitted by Clearinghouse Participants to the Clearinghouse is proprietary data and shall be used only for the purposes stated within the Participant's agreement with the Clearinghouse. The Clearinghouse has instituted reasonable controls to ensure that information it receives from Participants will be used only in accordance with applicable agreements and will be shared only with parties authorized to such information under applicable participant agreements or by law. Furthermore, the Clearinghouse has in place an information security program for protecting Participant's proprietary student information that fulfills the objectives set forth in the "Interagency Guidelines Establishing Standards for Safeguarding Customer Information", 66 Fed. Reg. 8616, February 1, 2001, (codified in Appendix B to 12 C.F.R. part 30.) 

The Clearinghouse's security program, in accordance with the aforementioned regulation, is designed to (i) ensure the security and confidentiality of any Customer Information provided to the Clearinghouse, (ii) protect against any anticipated threats or hazards to the security or integrity of Customer Information, and (iii) prevent unauthorized access to or use of Customer Information. Participants will also institute reasonable controls to ensure that information it receives from the Clearinghouse will only be used in connection with its obligations under its applicable agreement with the Clearinghouse and shall be shared only with persons authorized to such information under applicable participant agreements or by law.

Regarding Gramm-Leach-Bliley (GLB)

To the extent that a Financial Institution Participant shares any of its Customer Information with the Clearinghouse, the Clearinghouse recognizes that it is subject to the reuse and redisclosure limitations of the Joint Banking Agencies' regulations implementing Title V of the Gramm-Leach-Bliley Act, Public Law 106-102 (the "GLB Requirements") and as such is prohibited from disclosing or using any such Customer Information except (i) as necessary to carry out the purposes for which the information was disclosed or (ii) as may be otherwise be permitted under an exception contained in Section 216.14 or 216.15 or Section 313.14 or 313.15, as applicable, under the GLB Requirements in the ordinary course of business to carry out the purposes for which the information was disclosed.