For more than a quarter of a century, Nelnet Business Solutions, Inc. (Company), also doing business as FACTS Management, has served educational institutions, their students and families. Our policies, procedures and internal controls are annually tested through the rigors of third-party administered SSAE16, Sarbanes-Oxley, and Payment Card Industry (PCI) audits. In addition, we disclose our policies to you, our valued client, so that you are clear and can trust that we maintain a high level of discipline in our operations.
Payments are processed via electronic debits through the Automated Clearing House (ACH) network, credit cards, debit cards, checks, or money orders. Successfully processed funds (Custodial Funds) are deposited in a Custodial Account or a Credit Card Settlement Account. The Company complies with payment processing rules established by the National Automated Clearing House Association, the banking system and the credit card associations. Consumers are protected by these payment processing rules, and the Company observes these rules when interacting with Consumers on the behalf of the institution. The Company controls funds while held in custody in order to invest funds and manage risk, process return or failed items, and remit funds to institutions.
Under generally accepted accounting principles (GAAP), the Company is required to include Custodial Funds in its financial statements. Custodial balances are presented as restricted funds due to Client Institutions. Funds held as Custodial Funds are exempt from the Company’s creditors.
The Company benefits from Custodial Funds through reductions in bank service charges or interest earned on custodial balances.
The following policies govern our banking relationships and the investment of Custodial Funds.
The following policies govern the insurance of the Company:
The following policies govern external audits of the Company:
The Company stores and retains financial data on separate mirrored computer systems located in geographically dispersed locations. The purpose of this arrangement is to maintain, in a commercially reasonable manner, a backup of all data in the event that a disaster impacts our primary database. The locations also provide emergency power and dedicated, redundant Internet links.
The following policies govern the compliance program at the Company:
The security of funds is of paramount importance to the Company. We would be pleased to provide interested parties detailed information with respect to our banking relationships, insurance coverage, and our most recent audits of accounts or controls. Please contact your Regional Vice President or Account Manager. If you are unsure how to contact your Regional Vice President or Account Manager, please call the Company office at 866-412-4637. You may also e-mail us at email@example.com or visit our Web sites.
All polices are reviewed annually by the Company.