HU. Financial Aid Lender Relations Institutional Code of Conduct

Purpose

To comply with the Higher Education Opportunity Act (HEOA) (Public Law 110-315, Section 1011) regarding ethical lender relations with institutions of higher education receiving Title IV funds or has students who participate in private educational loans. This policy specifically addresses the Integrity Provisions of the act, by providing the required “Institution Code of Conduct” for South Plains College.

Conflict of Interest

South Plains College strictly prohibits all officers, employees and agents of South Plains College from having a conflict of interest or the appearance of conflict of interest with respect to student loans or other financial aid.

Training and Compliance

South Plains College shall administer and enforce this code of conduct by requiring all officers, employees and agents with responsibilities for student loans and financial aid to participate in annual compliance training.  The Director of Financial Aid shall provide, coordinate and document this annual training.

Gifts

South Plains College strictly prohibits all officers, employees and agents responsible for student loans or financial aid from receiving gifts from any lender, guarantor or servicer of educational loans.

A gift is defined as any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than $15 dollars (a de minimus amount).  The term includes a gift of services, transportation, lodging or meals whether provided in kind, by purchase of ticket, payment in advance, or reimbursement after the expense has been incurred.

Gift Exceptions

The term ‘gift’ shall not include any of the following:

 

Gifts to Family Members

A gift as defined in this policy that is given to a family member of an officer, employee or agent of the College or a gift to any other individual based on that individual’s relationship with the officer, employee or agent of the College shall be considered a gift to the officer, employee or agent if –

  • the gift is given with the knowledge and acquiescence of the officer, employee or agent; and

 

Contracting Arrangements

An officer, employee or agent of the College who is employed in the financial aid officer or who otherwise has responsibilities with respect to educational loans or other financial aid, shall not 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 consulting services, serving on an advisory council or otherwise advising such lender or affiliateContracting arrangements are not prohibited if;   

  • An SPC officer or employee who is not employed in the financial aid office and who does not otherwise have responsibilities with respect to educational loans, from performing paid or unpaid service on a board of directors of a lender, guarantor or servicer of educational loans;

 

Advisory Board Participation

SPC employees who are employed in the Financial Aid Office, or who otherwise have responsibilities with respect to educational loans or other student financial aid, and who serve on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, shall be prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, committee, or group.

Interaction With Borrowers

South Plains College will 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.

 

Staffing Assistance

South Plains College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing unless the assistance from the lender is related to:

  • Professional development training for financial aid administrators

 

Opportunity Pool Loan

An opportunity pool loan is a private education loan made by a lender to a student attending SPC or a family member of such a student that involves a payment, directly or indirectly by the college of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family. 

South Plains College will not request, accept or consider from any lender any offer of funds to be used for private educational loans as defined in section 140 of the Truth in Lending Act), including funds for an opportunity pool loan, to students in exchange for the College providing concessions or promises to the lender with—

  • a specified number of loans made, insured or guaranteed under this title;
  • a specified loan volume of such loans; or

 

Compliance

South Plains College understands and recognizes that failure to comply with the Higher Education Opportunity Act , specifically Section 1011 may result in sanctions imposed by the Secretary of Education that include limiting, terminating or suspending participation in title IV programs.

 

Approved by Executive Council 2/23/2009

 


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