It has. ND has the FUND, but it's focused on players already enrolled. They have no program for signing recruits, and have shown no indication they'll play that game.
They sell getting the kids paid once they've signed. Sam Hartman will most likely make $2M plus this year, for example -- but his transfer did not come with an upfront payment like many high school seniors are getting now. This is why they lost Keon Keeley and Payton Bowen last year, which in turn probably kept them from a top 5 class.
Is it effective? Who knows. But if Scott wants some NIL money upfront, he won't be getting it from ND.