Student Loan Code of Conduct
At Clark State we strive to provide the best customer service and experience to our students and the community.
Code of Conduct for Clark State College
As an institution of higher education and one that participates in Title IV programs, Clark State College has adopted this Code of Conduct. This code applies to all officers, employees and agents of the institution. This code is developed to ensure that the best customer service is provided to our students and their families and that they will receive impartial advice from our employees. It also ensures that there is no potential for, or appearance of conflicts of interest regarding student loans. Clark State College will abide by this code in its relationships with lenders, servicers and guarantors of education loans.
Employees will adhere to the following guidelines:
- Clark State will not enter into revenue-sharing arrangements with any lender. The Higher Education Opportunity Act defines revenue-sharing as any arrangement between an institution and a lender under which the lender makes Title IV loans to students attending the institution, the institution recommends the lender in exchange for fees or benefits, including revenue or profit sharing to the institution or its employees.
- No employee of the Financial Aid office, nor any officer or agent of the institution that has responsibilities with respect to education loans, may receive gifts from a lender, guarantor or servicer. A “gift” is defined as any gratuity, favor, discount, entertainment, loan or other item having more than a nominal value. “Gifts” do not include:
- a brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy;
- food, training or informational material provided as part of a training session designed to improve the service of a lender etc., if the training contributes to the professional development of the institution’s employee;
- favorable terms and benefits on an education loan provided to a student employed by the institution if those terms and benefits are comparable to those provided to all students;
- entrance and exit counseling as long as the institution’s staff are in control of the counseling and the counseling does not promote the services of a specific lender;
- philanthropic contributions from a lender, guarantor or servicer that are unrelated to education loans or any contribution that is not made in exchange for advantage related to education loans;
- state education grants, scholarships or financial aid funds administered on behalf of a State.
- No officer or employee of the institution’s Financial Aid office (or any one who has responsibilities with respect to education loans) may accept from lender, or affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on the behalf of a lender relating to education loans.
- The steering of borrowers to particular lenders or the delaying of loan certifications is prohibited. For any first time borrower, the institution may not assign, through award packaging or other method, the borrower’s loan to a particular lender. In addition, the institution may not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty agency.
- The institution, or any employee may not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specified loan volume, or preferred lender arrangement. An “opportunity pool loan” is defined as a private education loan made by a lender to a student (or the student’s family) that involves a payment by the institution to the lender for extending credit to the student.
- The institution may not request or accept from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training, educational counseling materials (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, non-recurring basis during emergencies or disasters.
- Employees of the financial aid office, or any employee or officer that has responsibilities with respect to education loans or financial aid, who serves on an advisory board, commission or group established by a lender or guarantor (or groups of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board.
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