Student Loan Practices Code of Conduct (Policy 5.100)

Authority:	F.S. 1001.64; 1004.65
Date Adopted:	6/08; Rev 05/09

 

Policy:

The District Board of Trustees recognizes that ensuring the integrity of the student financial aid process is critical to providing fair and affordable access to higher education in Florida. Therefore, the Board adopts the following policy, which is designed to avoid any potential for a conflict of interest between the College, its students or their parents in the student financial aid process. Accordingly, the College shall adhere to the following principles in the College's financial aid operations:

1. College employees should receive no personal benefit.
   
   
   1. No officer, trustee or employee of the College shall accept anything of more than nominal value (not to exceed $100.00) on his or her behalf or on behalf of another person or entity from any Lending Institution.
      
      
      1. Cash, stocks, gifts, entertainment, expense-paid trips, etc. should never be accepted from a Lending Institution.
      2. An individual should never receive payment or reimbursement from a Lending Institution for lodging, meals or travel to conferences or training seminars.
   2. An office, trustee or employee of the College may:
      
      
      1. Conduct non-College business with any Lending Institution and, subject to state law, receive value in connection with such non-College business, so long as such value is not intended to influence the officer, trustee or employee in conducting College business;
      2. Conduct College business and, subject to state law, receive value on behalf of the College that is unrelated to the student loan activities of the Lending Institution;
      3. Attend conferences and meetings of tax-exempt organizations that are funded or sponsored by more than one entity and, subject to state law, receive materials, refreshments, and other things of similar nominal value provided at such professional conferences and meetings; and
      4. Hold membership in, serve on the board of, or participate in the activities of any tax-exempt organization and, subject to state law, receive travel reimbursements and other things of similar nominal value from the tax-exempt organization for such activities.
2. College employees should not serve on lender advisory boards.
   
   
   1. No officer, trustee or employee of the College who makes financial aid decisions for the College or who is employed in, supervises or otherwise has responsibility or authority over the College's financial aid office serve as a member or participant of a student loan advisory board of a Lending Institution or any reimbursement of expenses for such service.
   2. Any officer, trustee or employee of the College who serves as a member or participant of a Lending Institution board shall recuse himself or herself from any board discussions regarding the College's financial aid operations and abstain from voting on matters germane thereto.
3. The College should not provide any advantage to a Lending Institution.
   
   
   1. The College shall not accept anything of value from any Lending Institution in exchange for any advantage or consideration provided to the Lending Institution related to its student loan activities, including but not limited to revenue-sharing, printing costs or below-cost computer hardware or software
   2. The College shall not allow any Lending Institution to:
      
      
      1. Staff the College's financial aid office at any time: or
      2. Communicate with the College's student or their parents in such a manner as to create the impression that the Lending Institution is an employee or agent of the College in connection with the College's student financial aid operations, including through the use of mascots, logos, etc.
   3. The College shall not enter into any agreement with a Lending Institution to provide alternative (i.e., non-federal or "opportunity") student loan programs if the provision of such alternative loan programs prejudices other students of the College or their parents.
4. The College should make appropriate use of any Lender Resources Lists.
   
   
   1. If the College decides to promulgate a list or lists of lenders for student loans or similar designation (" Lender Resources List"), the determination of Lending Institutions for inclusion on the Lender Resources List shall be based on the lenders currently known to be doing business with the College's students and their parents without regard to the financial interests of the College.
   2. Any Lender Resources List shall clearly explain:
      
      
      1. Student and their parents are free to select the Lending Institution of their choice and will suffer no penalty imposed by the College from using a Lending Institution that is not a " lender resource";
      2. Students and their parents are not required to use any of the "lender resources" currently listed;
      3. Where to find information on other Lending Institutions for student loans;
      4. The College will promptly certify any loan from any Lending Institution selected by a borrower, in accordance with U.S. Department of Education regulations:
      5. The process the College utilized to list "lender resources", including but not limited to the criteria used and the relative importance of such criteria;
      6. Where to find information as to competitive interest rates, terms, and conditions of federal loans;
      7. Where to find explanatory information germane to the interest rate, loan servicing or other benefits offered by " lender resources"; and
      8. Where to find information on any agreements by " lender resources" to sell their loans to other Lending Institutions.

The College shall review any Lender Resources List at least annually to determine that the information appearing on the list is accurate and that any website links are still viable.