REVIEWER: Diane Freundel, assistant vice president of compliance and contract review for American Education Services.

BACKGROUND: American Education Services (AES) is a not-for-profit, student aid services organization. It manages nearly $43 billion in total assets and services, and close to 4 million students through its guaranty, servicing and financial aid processing systems. Unlike for-profit organizations, AES "shareholders" are America's students and families. The funds generated through its extensive operations are used to improve higher education opportunities; lower the cost of financial assistance; streamline processes for the financial aid community; and empower students, families, schools and lenders through its industry-leading, Web-based technology.

PLATFORMS: i/Lytics SECURE from Innovative Systems (Innovative) is implemented throughout the AES processing environment, which includes 15 independent databases - some on mainframe and others on open systems platforms, including AIX and Windows/NT.

PROBLEM SOLVED: In reviewing new regulations that require student loan lenders to screen applicants against the U.S. Treasury's Office of Foreign Assets Control (OFAC) sanctions list, AES officials realized that we were in a position to implement a comprehensive compliance strategy to fulfill our own screening requirements while at the same time assisting our lenders in meeting their respective obligations.

PRODUCT FUNCTIONALITY: The goal of the AES compliance program is to ensure that no grants or loans are extended to individuals on the OFAC sanctions list. AES relies on i/Lytics SECURE's powerful matching capabilities to precisely screen student loan applicants and to identify any hits against the OFAC list. Before the new software went into operation, Innovative's delivery professionals worked with the AES team to improve the data quality within the 15 different databases in order to optimize the screening process. In all, the total implementation and data cleanup effort took less than three weeks. i/Lytics SECURE is working great. In addition to the product's ability to confidently minimize false-positives and their associated time and costs, we're also taking advantage of the product's ability to generate our own internal safe lists and risk lists, which help us to make better business decisions as well as meet our compliance obligations.

STRENGTHS: The most important strength is the product's ability to conform its matching logic and process to meet our business rules, which minimizes timely and costly review of false-positive matches. In addition, the product's easy-to-use review utility allows reviewers to quickly investigate and appropriately resolve any flagged records, eliminating redundant review in the future.

WEAKNESSES: There are limitations to the types of customized activity and usage reports that AES is able to generate.

SELECTION CRITERIA: First, we needed a solution that would satisfy the organization's current compliance requirements, but also demonstrated a capacity to satisfy a breadth of compliance requirements to help the organization meet new and changing requirements in the future. Second, the group wanted a solution that was easy to use for both technology and business users. Finally, the cost of the total solution was very important. To satisfy its internal screening requirements as well as to extend this mission critical service to its lenders, the team understood that the implementation environment would be complex. The cost of implementing and maintaining the software over time was as important - if not more important - than the cost of the software alone. Innovative Systems' i/Lytics SECURE best met these three important criteria.

DELIVERABLES: AES is successfully running i/Lytics SECURE to ensure compliance with its new regulatory screening requirements. The business users have easily transitioned to reviewing the results and reports generated by the new screening process.

VENDOR SUPPORT: According to Matt Stefanski, an AES technical compliance specialist and part of the implementation team, "Overall, this was one of the smoothest new product implementations that I've ever seen. The Innovative delivery professionals were very knowledgeable and experienced, and very easy to work with."

DOCUMENTATION: The documentation, although complete, was not immediately easy to understand by the business community.

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