Title IV Loans Code of Conduct
This code of conduct applies for all the officers and employees of the institution that are directly involved in processing American Student Loans and prohibits all members of Staff handling U.S loan applications from any of the practices listed below and has been distributed amongst all relevant staff.
- A ban on revenue-sharing arrangements with any lender. Revenue- sharing is defined as any arrangement between an institution and a Title IV lender. The institutions will not recommend a lender or loan product in exchange for any fee or other material benefit, including profit sharing and revenue.
- Employees involved in financial aid are prohibited from soliciting or accepting any gifts from any lender, guarantee agency or loan servicer. A gift is defined as any gratuity, favour, discount, entertainment, hospitality, loan or other item having monetary value of more than a de minimus amount. A Gift does not include brochures, training or workshops provided if contributing to the professional development of the institutions employee; Food or informational material provided as part of a training session; entrance and Exit counselling as long as the institutional staff are in control of the counseling session and the services of a specific lender are not promoted; Philanthropic contributions from a lender, guarantor or servicer that are not made in exchange for advantage related to loans; State education grants, scholarships or financial aid Funds administered by the state.
- A ban on contracting arrangements. No institutional employee involved in financial Aid may accept from a lender, or an affiliate of any lender, any fee, payment or financial benefit as compensation from any type of consulting arrangement or contract to provide services to or on behalf of a lender in relations to loans.
- A prohibition against steering borrowers to particular lender or delaying loan certifications. For any first time borrowers the institution may not assign the borrowers loan to a particular lender. In addition the institution may not refuse to certify, or delay the certification, of any loan based on the lender selection.
- A Prohibition on offers of funds for private loans. An institution may not accept or request any offer of funds for private loans to students in exchange for providing concessions or guarantees of volume
- A ban on staffing assistance. An institution may not request or accept from any lender assistance with calls centre staffing or financial aid office staffing. Lenders may provide support for professional development or educational counseling.
- A ban on advisory board compensation. Institutional employees involved in US loans, who serve on an advisory board, commission or group established by a lender or guarantor is prohibited from receiving anything of value from the lender or group, except reimbursement for reasonable expenses incurred by the employee for serving on the board.