Student Loan Code of Conduct
POLICY STATEMENT FOR STUDENT LOAN CODE OF CONDUCT:
Sinclair Community College (Sinclair) complies with the Higher Education Act and the U.S. Department of Education (ED) regulation to publish and enforce the following guidelines to avoid any conflict of interest between Sinclair and students or their parents in the student financial aid process. The purpose of this Student Loan Code of Conduct is to ensure the integrity of the student aid process and ethical conduct of Sinclair officers, employees, and agents with respect to student loan practices. For more information see 34 CFR 601.21 and 34 CFR 668.14(b)(27).
For purpose of this code of conduct, Lending Institution means:
Sinclair prohibits its employees from entering into any type of revenue-sharing arrangement with any lender, guarantor or servicer. The term “revenue-sharing arrangement” means an arrangement between an institution and a lender in which:
Employees of the Financial Aid & Scholarships office are prohibited from soliciting or accepting any gift or anything of more than a de minimus value from a lender, guarantor, or education loan servicers.
Family members include a person's:
A gift does not include:
PREFERRED LENDER STATUS
Sinclair participates in the following loan programs that provide student and parent loans through the U.S. Department of Education: William D. Ford Federal Direct Loan Program Sinclair provides a preferred lender list from which to select a lender for a private education student loan. The list is available on FASTChoice and provides a list of preferred lenders based on low interest rates, no origination fees, timely processing, total loan volume, and electronic funds transfer capabilities. Sinclair will certify private loans from any lender. Terms, fees, and borrowing limits of private loans differ. Borrowing a private loan is a decision that should be made with careful consideration.
Sinclair prohibits any employee, officer or agent employed by the financial aid office who otherwise has responsibilities with respect to federal or private education loans from accepting from any lender or affiliate 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 the lender.
DIRECTING BORROWERS OR DELAYING LOAN CERTIFICATIONS
Sinclair prohibits the assignment of a first-time borrower to a particular lending institution through award packaging or other methods. Sinclair will not assign a borrower's private student loan to a particular lender. All decisions shall be made by the borrower in his/her independent review of borrower benefits and lender services. Further, Sinclair will not refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.
OPPORTUNITY POOL LOANS
Sinclair prohibits any employee, officer or agent from requesting or accepting from any lender any offer of funds to be used for private education loans including an opportunity pool loan to students in exchange for concessions or promises regarding providing the lender with;
Private education loans include an opportunity pool loan which means a private education loan made by a lender to a student or family member of the student attending the institution 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.
Sinclair prohibits accepting or soliciting staffing assistance from a lending institution, including but not limited to call center staffing or financial aid office staffing. However, this does not prohibit requesting or accepting professional development training for aid officers, or requesting or accepting counseling, financial aid literacy, or debt management materials for borrowers, if the material discloses that the lender prepared or provided the materials.
ADVISORY BOARD COMPENSATION
Employees of the Financial Aid & Scholarships office who serve on an advisory board, commission or group established by a lender or guarantor, must not receive anything of value from the lender or guarantor except that the employee may be reimbursed for reasonable expenses incurred for serving on such advisory board, commission or group.
- Last Revised: 10/03/2013