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  3. January 2007

Re: ACH for electronic checks processing

Hey Mike,

We do ACH for Student Loan payments, but we gather our information via a
paper application, and don't get any information via the web, yet.  I would
expect that the auditors would prefer that information that is private and
confidential would be handled with all the care you would handle the credit
card numbers.  If you have the account number and routing number, and access
to a lender that will accept ACH transactions via a file or entered on a web
site, you could do bad things to a person's account and bank balance.

Just my 2 pennies worth

Jim

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