Student Loan Code of Conduct
The Higher Education Opportunity Act (HEOA) of 2008 includes the requirement that an institution participating in a Title IV loan program must develop, publish, administer, and enforce a code of conduct related to administration of the Title IV loan programs. Pomeroy College of Nursing at Crouse Hospital adheres to the following student loan code of conduct and applies the code of conduct to its officers, employees and agents of the school.
Prohibition of preferred lender arrangements/lists. A preferred lender arrangement is defined as an arrangement or agreement, between a lender and covered institution, in which a lender provides education loans to students (or the students’ families) and the covered institution recommends, promotes or endorses the education loan products of the lender. Officers and employees of Pomeroy College of Nursing at Crouse Hospital may not recommend, promote or otherwise endorse specific lenders or the education loan products of any lender.
Ban on revenue-sharing arrangements with any lender: The HEOA defines “revenue-sharing arrangement” as any agreement between an institution and a lender under which the lender makes Title IV loans to students attending the institution (or to families of those students), 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. Pomeroy College of Nursing at Crouse Hospital prohibits participation in any revenue-sharing arrangements by the institution or by its officers, employees, or agents.
Ban on employees of the financial aid office receiving gifts from a lender, guaranty agency or loan servicer: No officer or employee the Pomeroy College of Nursing, Office of Financial Aid (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 nominal amount. A “gift” does not include (1) a brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy, such as a brochure, workshop, or training; (2) 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 officers, employees, or agents; (3) 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; (4) 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; (5) philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans or any contribution that is not made in exchange for an advantage related to education loans, and; (6) State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
Ban on contracting arrangements. No officer or employee of the Pomeroy College of Nursing at Crouse Hospital, Office of Financial Aid (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.
Prohibition against steering borrowers to particular lenders or delaying loan certifications. For any first-time borrower, Pomeroy College of Nursing at Crouse Hospital may not assign, through the award packaging or other methods, the borrower’s loan to a particular lender. In addition, Pomeroy College of Nursing at Crouse Hospital 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.
Prohibition on offers of funds for private loans. Pomeroy College of Nursing at Crouse Hospital 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.
Ban on staffing assistance. Pomeroy College of Nursing at Crouse Hospital may not request or accept from any lender any assistance with call center staffing or financial aid 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.
Ban on advisory board compensation. Any employee of the Pomeroy College of Nursing at Crouse Hospital, Office of Financial Aid (or employee who otherwise has responsibilities with respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or 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 for serving on the board.
