OCU University Student Financial Services Code of Conduct
Section 487(a) (25) of the Higher Education Opportunity Act (HEOA), enacted on Aug. 14, 2008, requires that if an institution lists lenders for students to review, the institution must develop, publish, administer, and enforce a code of conduct. The code of conduct applies to the officers, employees, and agents of the institution.
As a participant in federal loan programs, OCU University Student Financial Services shall ensure that employees adhere to the following:
- Employees of Student Financial Services may not enter into revenue-sharing arrangements with any lender. The HEOA defines "revenue-sharing arrangement" as any arrangement between an institution and a lender under which:
- the lender makes Title IV loans to students attending the institution (or to the families of those students); and
- the institution recommends the lender or the loan products of the lender and, in exchange, the lender pays a fee or provides other material benefits, including revenue or profit-sharing, to the institution or to its officers, employees, or agents;
- Employees of Student Financial Services may not accept gifts from a lender, guaranty agency or loan servicer. No officer or employee of an institution's Student Financial Services office (or an employee or agent who otherwise has responsibilities with respect to educational loans) may solicit or accept any gift from a lender, guarantor, or servicer of education loans. A "gift" is defined as any gratuity, favor, discount, entertainment, hospitality, loan, or other item having monetary value of more than a de minimums amount. However, a gift does not include:
- A brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy, such as a brochure, workshop or training;
- Food, training, or informational material provided as part of a training session designed to improve the service of a lender, guarantor, or servicer if the training contributes to the professional development of the institution's officer, employee or agent;
- 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 at the institution;
- 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, and;
- State education grants, scholarships, or financial aid funds administered by or on behalf of a State;
- Employees of Student Financial Services may not enter into any contracting arrangements with a lender relating to education loans. No officer or employee of an institution's Student Financial Services office (or employee or agent who otherwise has responsibilities with respect to education loans) may accept from a lender, or an 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 behalf of a lender relating to education loans;
- Employees of Student Financial Services may not direct borrowers to particular lenders or delay loan certifications. For any first-time borrower, an institution may not assign, through the award packaging or other methods, 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;
- Employees of Student Financial Services may not accept offers of funds for private loans. An institution 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 specific number of Title IV loans made, insured, or guaranteed, a specified loan volume, or a 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;
- Employees of Student Financial Services may not accept staffing assistance. An institution may not request or accept from any lender any assistance with call center staffing or Student Financial Services 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, nonrecurring basis during emergencies or disasters; and
- Employees of Student Financial Services may not receive advisory board compensation. An employee of an institution's Student Financial Services office (or employee who otherwise has responsibilities with respect to education loans or Student Financial Services office) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group 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.
Failure to adhere to this Code of Conduct may result in disciplinary action in accordance with applicable university policies and procedures, up to and including termination of employment.
