Financial Aid Code of Conduct

ANCILLA COLLEGE CODE OF CONDUCT RELATED TO STUDENT LOAN ACTIVITIES

Ancilla College, as a participant in the federal loan programs, is required to have a code of conduct applicable to the institution’s officers, employees, and agents.  The requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law August 2008.  In accordance with this requirement, Ancilla College has established the following code of conduct as related to student loan activities.

Conflict of Interest

No employee shall have a conflict of interest with respect to any education loan or other student financial aid for which the employee has responsibility. Employees may not process any transaction related to their own personal financial aid eligibility or that of a relative without review of said financial aid package by another financial aid/business office employee.

Ban on Revenue Sharing Arrangements

Ancilla College has not, and will not in the future, enter into any revenue‐sharing arrangements with any lender. Revenue‐sharing arrangements include but are not limited to the institution recommending a specific lender or loan products in exchange for the lender paying a fee or providing other material benefits, including revenue or profit sharing, to the institution, officer, employee, or agent.

Gift Ban

Employees or their family members may not solicit and/or accept any gifts with a value of more than a de minimus amount from lenders, guarantors, or servicers of education loans.

Prohibition on Contracting

Employees who work in the Financial Aid Office or who have responsibilities related to education loans may not accept from any lender or lender affiliate any fees, payments, or other financial benefit as compensation (including the opportunity to purchase stock) for any type of consulting arrangement or other contract to provide services to a lender relating to education
loans.

Interaction with Borrowers

The College will not refuse to certify, or delay certification of, any loan based on the borrower’s choice of lender.

Prohibition on Offers of Funds for Private LoansAncilla College does not request or accept from any lender an offer of funds to be used for private education loans in exchange for promises to the lender with regards to the number of
loans certified, specific loan volume or preferred lender arrangement.

Co‐branding

The College will not permit a private educational lender to use the College’s name, emblem, logo or any other words, pictures or symbols associated with the College to imply endorsement of private education loans by that lender.

Ban on Staffing Assistance

The College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. However, nothing in this section prevents the College from accepting assistance from a lender or guarantor in regards to: professional development training for College staff, providing educational counseling materials, financial literacy materials or debt management materials to borrowers.

Advisory Board Compensation

No employee who serves on an advisory board, commission or group established by a lender, guarantor, or group of lenders or guarantors may receive anything of value from the previous listed entities in return for that service.

Reimbursement of Expenses

Expenses incurred while attending professional association meetings, conferences, or in connection with service on an advisory board or commission must be paid by the College. Payment for entertainment expenses may also not be accepted from any lender, guarantor or servicer. Meals offered as part of meetings, conferences, professional development activities or other events may be accepted if all participants in the meeting or event are offered the meals, or if the meals are included as part of the registration fee.