STUDENT LOAN PROGRAM

CODE OF CONDUCT

Revenue Sharing Ban: The College will not enter into revenue-sharing arrangements with any lenders that result in a financial benefit to the College or its employees.

Gift Ban:  Employees and officials will not solicit or accept gifts, cash or other payments from any lender, guarantor, or servicer. The term “gift” means any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than $10.00. This ban does not include the following:

• Brochures or training material related to default aversion or financial literacy.
• Food, training or information materials that contributes to the professional development of individuals attending the training.
• Entrance and exit counseling that does not promote the services of a specific lender.
• Philanthropic contributions from a lender, guarantor or servicer unrelated to education loans.
• State education, grants, scholarships or financial aid funds administered by or on behalf of the state.

Advisory Board Compensation: Employees with responsibilities related to student loans will not accept compensation for serving on the advisory board of any lending institution or guarantor.

Opportunity Pools: The College will not request or accept from any lender any offer to be used for private education loans, including funds for an opportunity pool loan, in exchange for providing concessions or promises of a specified volume of Title IV loans, or a preferred lender arrangement for Title IV loans.

Contract Arrangement Prohibition: Employees with educational loan responsibilities will not receive any remuneration from a lender as compensation for any type of consulting arrangement, or other contract to provide services relating to education loans.

Staffing Assistance Ban: The College will not request nor accept any assistance with financial aid staffing from any lender of educational loans.

Assignment of Lenders: The College will not assign a loan to a particular lender for any borrowers through award packaging or other methods.

Recommended Lender List: If the College develops and publishes a list of recommended or preferred lenders (“recommended lender list”), the College will do so based solely on the best interests of student and parent borrowers. The College will prominently disclose on all publications of a recommended lender list:

• The process and criteria by which the list was assembled.
• Comparative information regarding interest rates and other benefits offered by the Lenders.
• Borrowers have the right and ability to select lenders not included on the list.

Loan Certification: The College will not refuse to certify or delay certification of any loan based on the borrower’s selection of a particular lender or guarantor.

Private Loans as a Last Resort: The College will not certify student eligibility for a private loan without first informing the borrower of the availability of federal grants and loans, and that federal loans may provide more advantageous terms than private loans.