Policies + Guidelines

I. Prohibition of Certain Remuneration to College Employees

1. Officers, trustees, directors, employees, or agents of the College are prohibited from accepting anything of more than nominal value on his or her own behalf or on behalf of another from or on behalf of a Lending Institution, except that this provision shall not be construed to prohibit any officer, trustee, director, employee, or agent of the College from conducting non-College business with any Lending Institution. As used in the preceding sentence and throughout this Code, a Lending Institution is defined as:

(a) Any entity that itself or through an affiliate engages in the business of making loans to students, parents or others for purposes of financing higher education expenses or that securitizes such loans; or

(b) Any entity, or association of entities, that guarantees education loans.

2. Notwithstanding the prohibitions in subsection I.1 or any other provision of this Code of Conduct:

(a) The College may hold membership in any nonprofit professional association;

(b) A College officer, trustee, director, employee, or agent who is not employed in the financial aid office of the College and does not have responsibilities with respect to higher educational loans or financial aid, may serve as an Outside Director of a Lending Institution or Trade Associate and receive Compensation at the Lending Institution’s or Trade Association’s established compensation rates for Outside Directors, provided that any College officer, trustee, director, employee, or agent serving on the board of the Lending Institution or Trade Association is precluded from participating in such board’s discussion or decisions that might affect the interests of the College and thereby be a conflict of interest, and provided further that such College officer, trustee, director, employee or agent receives annual written notice of the requirements of this Code of Conduct.

3. The prohibition set forth in the subparagraph I.1 above shall include, but not be limited to, a ban on any payment or reimbursement by a Lending Institution (not including state agency boards and/or similar governmental or non-profit entities) to a College employee for lodging, meals, or travel to conferences or training seminars.

II. Limitations on College Employees Participating on Lender Advisory Boards

The College shall prohibit any officer, trustee, director, employee, or agent of the College from receiving any remuneration for serving as a member or participant of an advisory board of a Lending Institution, or receiving any reimbursement of expenses for so serving, provided, however, that participation on advisory boards that are unrelated in any way to higher education loans shall not be prohibited by the Agreement.

III. Prohibition of Certain Remuneration to the College

The College may not accept on its own behalf anything of value from any Lending Institution in exchange for any advantage or consideration provided to the Lending Institution related to its education loan activity. This prohibition shall include, but not be limited to, (i) “revenue sharing” by a Lending Institution with the College, (ii) the College’s receipt from any Lending Institution of any computer hardware for which the College pays below-market prices and (iii) printing costs or services. Notwithstanding anything else in this paragraph, the College may accept assistance as contemplated in 34 CFR 682.200(b)(definition of “Lender”)(5)(i) and nothing contained herein shall prohibit or restrict the College’s “School as Lender” programs or any successor or affiliated loan programs which are permitted by law.

IV. Alternative Loan Preferred Lender Lists

In the event that the College promulgates a list of preferred or recommended lenders or similar ranking or designation (“Preferred Lender List”) with respect to alternative loans, then:

(a) Every brochure, web page or other document that sets forth a Preferred Lender List must clearly disclose the process by which the College selected lenders for said Preferred Lender List, including but not limited to the criteria used in compiling said list and the relative importance of those criteria.

(b) Every brochure, web page or other document that sets forth a Preferred Lender List or identifies any lender as being on said Preferred Lender List shall state in the same font and same manner as the predominant text on the document that students and their parents have the right and ability to select the education loan provider of their choice, are not limited to or required to use any of the lenders on said Preferred Lender List, and will suffer no penalty from the College for choosing a lender that is not on said Preferred Lender List. In addition, each such brochure, web page or other document that sets forth a Preferred Lender List shall include a statement that the College is required to process, and shall not delay the processing of, the documents required to obtain a loan from any eligible lender the student or parents select.

(c) The College’s decision to include a Lending Institution on any such list and the College’s decision as to where on the list the Lending Institution’s name appears shall be determined solely by consideration of the best interests of the students or parents who may use said list without regard to the pecuniary interests of the College.

(d) The constitution of any Preferred Lender List shall be reviewed no less than annually.

(e) No Lending Institution shall be placed on any Preferred Lender List unless the said lender provides assurance to the College and to student and parent borrowers who take out loans from said Lending Institution that the advertised benefits upon repayment will continue to inure to the benefit of student and parent borrowers regardless of whether the Lending Institution’s loans are sold.

(f) No Lending Institution of which the College is expressly aware that has an agreement to sell its loans to another unaffiliated Lending Institution shall be included on any Preferred Lender List unless such agreement is disclosed therein in the same font and same manner as the predominant text on the document in which the Preferred Lender List appears.

(g) No Lending Institution shall be placed on any one of the College’s Preferred Lender Lists or in favored placement on any one of the College’s Preferred Lender Lists for a particular type of loan, in exchange for benefits provided to the College or to the College’s students in connection with a different type of loan.

(h) Every Preferred Lender List shall include at least three unaffiliated lenders for Title IV loans and at least two unaffiliated lenders for private education loans, and for any affiliated lenders on the list, the College shall disclose the specifics of such affiliation.

(i) The College may provide a list of allowable and prohibited practices and services that Lending Institutions may provide.

(j) The College shall not allow any Lending Institution to use the name or any symbol or logo of the College in marketing any loan in any way that implicates that the College endorses the loans offered by the Lending Institution.

(k) The College shall prohibit the use of the logo of any Lending Institution on the College’s financial aid materials.

V. Prohibition of Lending Institutions’ Staffing of College Financial Aid Offices

The College shall prohibit employees or other agents of a Lending Institution from being identified to students or prospective students of the College or their parents as an employee or agent of the College. No employee or other agent of a Lending Institution may staff the College financial aid offices at any time.

VI. Prohibition of Opportunity Loans

The College shall not arrange with a Lending Institution to provide any “Opportunity Loans.” The term “Opportunity Loans” shall mean agreements which provide that the Lender will make loans up to a specified aggregate amount to students with poor or no credit history, or international students who the Lender claims would otherwise not be eligible for the Lender’s alternative loan program.

VII. Conflict of Interest

This Code shall prohibit a conflict of interest or the appearance of a conflict of interest with the responsibilities of any College officer, employee or agent with respect to student loans or other financial aid.

VIII. Training

The College shall require all of its officers, employees and agents with responsibilities with respect to student loans or other financial aid annually to obtain training, and/or to acknowledge compliance, with this Code of Conduct.