Code of Conduct
In accordance with the Higher Education Opportunity Act (HEOA) institutions of higher learning are to develop and comply with a code of conduct with regards to the administration of educational student loans. The purpose of this code is to prohibit conflict of interest between the makers of these loans and personnel of Thomas More College at the institution Thomas More's primary commitment with respect to student loans is ensure that borrower benefits and services are in the best interest of the student and parent borrowers.
The following provisions will serve as a guide in meeting this requirement:
- Thomas More College is prohibited from entering into any revenue sharing arrangement with any lender. Revenue sharing arrangement is defined as arrangement between a covered institution and a lender under which:
Employees of the financial aid office or others who otherwise have responsibilities with respect to educational student loans must not solicit or accepts gifts from a lender, guarantor, or a loan servicer provider. The term gift means any gratuity, favor, discount, entertainment, loan, or other item having a monetary value 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 incurred.
Financial Aid personnel or other College personnel who are otherwise responsible with respect to educational student loan must not accept from any lender or affiliate of any lender any fee, payment, or other financial benefit 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 educational student loans.
Thomas More College will not assign, through award packaging or other methods, lenders to any first time borrower; or refuse to certify or delay the certification of any loan based on the borrower's selection of a particular lender or guaranty agency.
The College will not request or accept from any lender any offer of funds to be used for private education loan to students in exchange for the institution providing concessions or promises regarding providing the lender with:
- A lender provides or issues educational student loans to students or families of
such students attending the institution; and
- The institution recommends the lender or loan product of the lender and in
exchange, the lender pays a fee or provides other material benefits, including
revenue or profit sharing, to the institution.
The College will not request or accept from any lender any assistance with financial aid office staffing.
Any Thomas More College financial aid office personnel or anyone else who has educational student loan responsibilities who serves on an advisory board for a lender or guarantor will not receive anything of value from the lender or guarantor except reimbursement for reasonable expenses incurred while serving on such advisory board, commission or group.
- A specific number of educational student loan;
- A specific loan volume for such lender; or
- A preferred lender arrangement for such loans.