Student fee protection information for auditors

Some of the key things that should be considered when auditing private training establishments (PTEs)

How are fees are deposited?

Are all student fees deposited directly into the trust account, or if deposited with the PTE, are they transferred to the trust account by close of business the next day?

Are all fees protected?

Are all fees protected in the trust account, including tuition and material fees, registration fees, and administration fees?

These fees should be included in the regular drawdowns, not taken separately at the beginning of the programme or micro-credential.

How are drawdowns paid?

You need to consider how drawdowns are paid. Possible ways include:

  • 20% of the tuition fees, to a maximum of $3,000, after the expiry of the refund period
  • the balance paid out in arrears, unless the programme or micro-credential is ‘conditions-dependent’, in which case the fees should be drawn down as tuition is delivered
  • A lesser drawdown arrangement is permitted, but a greater drawdown arrangement is not allowed under the Education and Training Act.

Agent commissions and incentives

Does the PTE top up the trust account for agent commissions or incentives which are deducted from the student fees before they are paid over by the agent?

Is holiday time included?

Does the length of time covered in the trust account include any holiday time the student takes during the programme or micro-credential, including but not limited to, any Christmas holiday leave?

Are there signed schedules?

Does the PTE obtain signed schedules from the student, acknowledging who the trustee is, and the payment details to the PTE from the trust account? (Examples are included as Schedules 3 and 5 of the Trust Deeds).

If the student is under 18 years, are the schedules cosigned by a parent or legal guardian?

Does the PTE only draw down fees as per the payment schedules?

Withdrawal and refund processes

Are procedures clear and available?

Does the PTE have clear withdrawal and refund procedures?

Are they available for the student to obtain, and does the PTE follow them?

Does the PTE's refund policy comply with the Trust Deed and Education and Training Act?

If a student stops their studies during refund period

Does the PTE allow students who stop participating in their studies during the refund period to withdraw with a refund, even if they have not completed the withdrawal procedures during the refund period?

How are refunds paid?

Does the trustee refund directly to the student, or is the refund paid to the PTE to transfer to the student? If the latter, is all the refund passed on to the student?

Are obligations completed on time?

Does the PTE complete all required student fee protection obligations on time? The PTE cannot be student fee protection-compliant if it is not completing quarterly attestations to its trustee where applicable.

Accommodation and living expenses

Do accommodation and living expenses go to the student immediately after the PTE receives the money?

Accommodation and living expenses should also be protected in the trust account.

Accommodation can be paid up to one month in advance if agreed in writing with the student, and living expenses can be paid as agreed in writing with the student.

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