Nelnet Business Solutions/Nelnet Campus Commerce
For more than a quarter of a century, Nelnet Business Solutions, Inc. (Company), also doing business as Nelnet Campus Commerce, 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.
Processing of Payments
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.
Accounting For Custodial Funds
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.
Accounts and Investment Policy
The following policies govern our banking relationships and the investment of Custodial Funds.
- Any Custodial Account for client institutions located in the United States shall be maintained with a domestic bank chartered in the United States of America, and regulated by one or more of the following federal agencies: the Federal Deposit Insurance Corporation, the Federal Reserve, or the Office of Comptroller of the Currency. The bank in which any such account is placed will maintain blanket bond coverage acceptable to the Company. Funds held in a Custodial Account are FDIC insured according to and to the extent provided by the FDIC. FDIC deposit insurance rules allow for deposits to be insured per individual depositor/payer when held by a fiduciary, custodian, agent, or guardian. Funds in the Credit Card Settlement Account are guaranteed by the depository bank and the credit card networks.
- Custodial Funds may be invested in securities or obligations issued, guaranteed, or reinsured, to the fullest extent allowed by law, by the United States government or an agency thereof. Custodial Funds invested in this manner are backed by the full faith and credit of the United States government or the appropriate agency thereof.
The following policies govern the insurance of the Company:
- General liability insurance coverage of the company will be maintained with insurance underwriters of not less than an AM Best Rating of A or better.
- General liability insurance coverage will be reviewed annually and will not be less than $1,000,000 per single occurrence and not less than $10,000,000 in the aggregate. The company will carry not less than $15,000,000 of excess liability coverage.
- Employee dishonesty insurance will be maintained at not less than $10,000,000 in the aggregate.
The following policies govern external audits of the Company:
- The Company will engage reputable firm(s) to conduct annual audit(s) necessary to test the internal controls and compliance of the Company with these policies.
- Nelnet, Inc. will engage a reputable firm to conduct an annual audit of its financial statements. Included in the audit will be a review of subsidiaries, including the Company.
Disaster Recovery and Contingency Planning
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.
Financial and Regulatory Compliance
The following policies govern the compliance program at the Company:
- The Company will make every effort to comply with applicable federal and state laws and regulations, ACH rules, and credit card regulations regarding financial privacy and the protection of financial data.
- The Company reviews its information and data security standards on a regular basis, including but not limited to qualified third-party reviews of its information and data security systems and compliance with ACH and credit card policies and procedures.
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 firstname.lastname@example.org or visit our Web sites.
All polices are reviewed annually by the Company.