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NBS Statement of Assurance
Posted 10/22/2008 08:00AM

NBS Statement of Assurance to the Institutions We Serve

For nearly a quarter of a century, Nelnet Business Solutions (also doing business as FACTS Management) has served educational institutions and their students and families with a trustworthy set of services. We place a high priority on making sure we comply with governmental, banking, and business regulations that affect our industry. We believe it is vital to be open, honest, and transparent about our policies and procedures because we understand the duty you feel toward your students and families and the consequent trust placed in us.

Privacy of Information
The most current version of our privacy statement is available at our Web sites (www.factsmgt.com or www.nelnetbusinesssolutions.com). Our privacy statement makes clear that the use of information we collect from individuals through our services is governed by your educational institution’s privacy policy. To protect nonpublic personal information from access by unauthorized parties, the Company maintains physical, procedural and electronic safeguards.

Banking Procedures and Regulations
As a large user of the Automated Clearing House (ACH) network, NBS/FACTS participates extensively in ACH network activities. We are a member of NACHA (the ACH rule-making body), the Midwest Payment Exchange (one of NACHA’s 19 regional associations), and the Council for Electronic Billing & Payment (one of NACHA’s leadership councils). Through these affiliations we maintain an ongoing understanding of the operations of the electronic banking industry.

Credit/Debit Card Regulations
Our company maintains strong working relationships with representatives of the major credit card associations through our affiliations with our merchant processing banks. These relationships allow us to stay up-to-date with Payment Card Industry (PCI) Data Security Standards as well as regulations governing card authorizations and disputes/chargebacks.

Federal/State Laws and Regulations
NBS/FACTS must abide by applicable federal and state laws. Educational institutions have similar obligations. By using our service for many of your back-office processes, you can take advantage of our security and compliance programs, thereby enhancing your compliance with two important federal laws, the Family Educational Rights and Privacy Act (FERPA) and Gramm-Leach-Bliley Act (GLBA). FERPA is intended to prevent educational institutions from releasing personally identifiable information about students without their consent. GLBA requires financial institutions to implement safeguards to protect consumers’ nonpublic financial information. We have controls in place to satisfy such requirements.

A Final Note About Auditing and Testing of Controls
You can be confident in NBS/FACTS. We are independently audited on an annual basis under a variety of audit standards. We undergo financial audits to achieve Sarbanes-Oxley compliance, our control procedures are audited under the SAS 70 audit standard (an audit designed for service organizations like NBS/FACTS), and our data security is audited in compliance with applicable PCI data security standards. Our success is your success—each year we successfully collect and remit billions of dollars in payments due to the institutions we serve.

We would be pleased to provide you with information with respect to our banking relationships, insurance coverage, and our most recent audits. Please contact your Regional Vice President or the Company office at 866.315.1270 . You may also e-mail us at info@nelnetbusinesssolutions.com or visit our Web sites.

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