Prohibition of Certain Remuneration to College Employees No employee or agent of the College shall accept anything of more than nominal value on his or her own behalf or on behalf of another from or on behalf of a Lending Institution, except that this provision shall not be construed to prohibit any employee or agent of the College from conducting (a) non-College business with any Lending Institution; or (b) College business unrelated to education loans. As used in the preceding sentence and throughout the Student Loan Practices Code of Conduct, a Lending Institution is defined as:
The prohibition set forth in the previous paragraph shall include, but not be limited to, a ban on any payment or reimbursement by a Lending Institution to a College employee for lodging, meals, or travel to conferences or training seminars unless such payment or reimbursement is related solely to non-College business or College business unrelated to education loans.
Limitations on College Employees Participating on Lender Advisory Boards No employee or agent of the College shall receive any remuneration for serving as a member or participant of an advisory board of a Lending Institution, or receive any reimbursement of expenses for so serving, provided, however, that participation on advisory boards that are unrelated in any way to higher education loans shall not be prohibited by the Student Loan Practices Code of Conduct. This code shall not prohibit College employees from serving on the MOHELA Board.
Prohibition of Certain Remuneration to the College The College will not accept on its own behalf anything of value from any Lending Institution in exchange for any advantage or consideration provided to the Lending Institution related to its education loan activity. This prohibition shall include, but not be limited to:
Preferred Lender Lists In the event that the College promulgates a list of preferred or recommended lenders or similar ranking or designation (“Preferred Lender List”), then:
Prohibition of Lending Institutions’ Staffing of College Financial Aid Offices No employee or other agent of a Lending Institution may ever be identified to students or prospective students of the College or their parents as an employee or agent of the College. No employee or other agent of a Lending Institution may staff the College financial aid offices at any time.
Proper Execution of Master Promissory Notes The College shall not link or otherwise direct potential borrowers to any electronic Master Promissory Notes or other loan agreements that do not allow students to enter the lender code or name for any lender offering the relevant loan.
School as Lender If the College participates in the “School as Lender” program under 20 U.S.C. § 1085(d)(1)(E), the College may not treat School As Lender loans any differently than if the loans originated directly from another lender; all sections of the Student Loan Practices Code of Conduct apply equally to such School as Lender loans as if the loans were provided by another lender.
Prohibition of Opportunity Loans As used herein, “override pools,” “opportunity funds,” and “opportunity loans” refer to any agreement, understanding, or practice in which a lender applies more lenient loan underwriting criteria than it otherwise would to a certain class of loan applicants if the College meets certain milestones or metrics with respect to other loans with that lender, such as the number of loans initiated or in force, or the dollar amount of such loans, or where the lender agrees with the College to lend money to students outside the Federal Family Education Loan Program (FFELP), at the direction of the College, in exchange for the College dropping out of the federal direct loan program and/or marketing the lender’s separate FFELP loans to students.
The College shall not arrange with a Lending Institution to participate in any override pools, opportunity funds, or opportunity loans, as defined above, if the participation in such program(s) prejudices any other borrower.
LINE OF AUTHORITY
Responsible Office: President’s Office
Contact person in that office: Executive Assistant to the President
EFFECTIVE DATE: August 16, 2023
Presidential approval: August 16, 2023