In compliance with the Code of Conduct requirements outlined in the Higher Education Opportunity Act of 2008, the following Code is provided.
- Any list or lists of preferred or recommended lenders for student loans provided by the University shall be based on the best interests of the University's student and parent borrowers without regard to the financial interests of the University. The list will clearly explain that student and parent borrowers may use the lender of their choice.
- The institution shall not for any first-time borrower, assign, through award packaging or other methods, the borrower's loan to a particular lender; or refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency. NOTE: If the University participates in the Federal Direct Student Loan Program (FDSLP) then the University retains the right to process any federal student loan or federal Parent PLUS Loan through the Federal Direct Student Loan Program, as specified in federal regulations.
- The institution shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Nothing shall be construed to prohibit the institution from requesting or accepting assistance from a lender related to:
- professional development training for financial aid administrators;
- providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials
- The institution shall not enter into any revenue-sharing or opportunity pool arrangement with any lender. The term `revenue-sharing arrangement' means an arrangement between an institution and a lender under which a lender provides or issues a federal student loan to students attending the institution or to the families of such student and the institution recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other material benefits, including revenue or profit sharing, to the institution, an officer or employee of the institution, or an agent.
- An officer or employee of the institution who is employed in the financial aid office of the institution or who otherwise has responsibilities with respect to education loans, or agent who has responsibilities with respect to education loans, shall not:
solicit or accept any gift from a lender, guarantor, or servicer of education loans. The term 'gift' means any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.
The term 'gift' shall not include standard material, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training, food, refreshments, or informational material furnished to an officer or employee of an institution, or to an agent, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such training contributes to the professional development of the officer, employee, or agent; favorable terms and borrower benefits on an education loan provided to a student or parent borrower; philanthropic contributions to an institution from a lender, servicer, or guarantor of education loans that are unrelated to education loans or any contribution from any lender, or servicer that is not made in exchange for any advantage related to education loans.
- receive anything of value from a lender, guarantor, or group of lenders or guarantors, except that an employee who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors may be reimbursed for reasonable expenses incurred in serving on an advisory board, commission, or group.
- accept from any lender or affiliate of any lender any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.
The information provided above is in support of University policies and codes regarding employee conduct. Some examples of those policies and codes are listed below.