Student Loan Code of Conduct
The Higher Education Act of 1965, as amended, (HEOA) requires any institution of higher education, proprietary institution of higher education, postsecondary vocational institution, or institution outside the United States, as these terms are defined in 34 CFR part 600, that receives any Federal funding or assistance to develop a code of conduct with respect to Direct Program loans and private education loans with which the institution's employees and agents must comply. The code of conduct prohibits a conflict of interest with the responsibilities of an employee or agent of an institution with respect to Direct Program loans and private education loans.
The Code of Conduct provides that:
- Huntington College of Health Sciences (HCHS) does not participate in any preferred lending agreement with any lender of private educational loans; therefore, no employee or agents of the College shall recommend, promote, or endorse the education loan products of any lender.
- HCHS as an institution and all employees or agents must not enter into any revenue-sharing arrangement with any lender. A revenue-sharing arrangement is defined as an arrangement between a institution and a lender in which a lender provides or issues private education loans to students attending the institution or to the families of such students; and the institution recommends the lender or the loan products of the lender who in exchange, pays a fee or provides other material benefits, including revenue or profit sharing, to the institution, and/or agent.
- Any HCHS employee or agent who is employed in the financial aid office of the institution or who otherwise have responsibilities with respect to education loans, must not solicit or accept any gift from a lender, guarantor, or servicer of 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.
- Any HCHS employee or agent who is employed in the financial aid office of the institution or who otherwise has responsibilities with respect to education loans must 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 any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.
- Neither HCHS as an institution nor its employees or agents shall 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.
- HCHS must not request or accept from any lender any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for the institution guaranteeing the lender a specified number private education loans, a specified loan volume of such loans, or a preferred lender arrangement for such loans. The term opportunity pool loan means a private education loan made by a lender to a student attending the institution or the family member of such a student that involves a payment, directly or indirectly, by such institution 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.
- HCHS must not request or accept from any lender any assistance with call center staffing or financial aid office staffing.
- Any HCHS employee or agent who is employed in the financial aid office of the institution, or who otherwise has responsibilities with respect to education loans or other student financial aid of the institution, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, must not receive 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, commission, or group.