Code of conduct — student loan lender relationships
It is Columbia College’s desire to abide by the following Code of Conduct:
Prohibition of certain remuneration of school employees
- The college shall require and ensure that employees of the financial aid department of the college refrain from soliciting or accepting anything of other than nominal value from any entity (other than an institution of higher education or a governmental entity such as the U.S. Department of Education) involved in the making, holding, consolidating or processing of any student loans, including anything of value (including reimbursement of expenses) for serving on an advisory body or as part of a training activity of or sponsored by such entity. This provision shall not be construed to prohibit any member of the financial aid department or any agent of the college who exercises direct control over student financial aid decisions, from conducting (a) non-college business with any Lending Institution; or (b) college business unrelated to education loans.
- Nothing in this provision or throughout the Code of Conduct shall prevent the college from holding membership in any nonprofit professional association.
- The prohibition set forth in paragraph one (1) shall include, but not be limited to, a ban on any payment or reimbursement by a Lending Institution to a college employee for items of greater than nominal value, including lodging, meals, or travel related to the attendance of conferences or training seminars, unless such payment or reimbursement is related solely to non-college business or college business unrelated to education loans.
Limitations on school employees participating on lender advisory boards
- The college shall prohibit any financial aid professional, the employee to whom the director of financial aid directly reports and any agent, of the college who exercises direct control over financial aid decisions, from receiving any remuneration for serving as a member or participant of an advisory board of a Lending Institution, or receiving any reimbursement of expenses for so serving, provided, however, that participation on advisory boards that are unrelated in any way to higher education loans shall not be prohibited by the Code of Conduct.
Prohibition of certain remuneration to the college
- The college may not accept on its own behalf anything of value from any Lending Institution in exchange for any advantage or consideration provided to the Lending Institution related to its education loan activity. This prohibition shall include, but not be limited to, (i) "revenue sharing" by a Lending Institution with the college, (ii) the college’s receipt from any Lending Institution of any computer hardware for which the college pays below-market prices and (iii) printing costs or services. Notwithstanding anything else in this paragraph, the college may accept assistance as contemplated in 34 CFR 682.200(b)(definition of "Lender")(5)(i).
Preferred lender lists
In the event that the college promulgates a list of preferred or recommended lenders or similar ranking or designation ("Preferred Lender List"), then
- The constitution of a Preferred Lender List shall be reviewed no less than bi-annually;
- The college has the right to remove lenders at any time for performance issues or changes in terms of the loan;
- The Preferred Lender List must have at least three unaffiliated lenders;
- The college must disclose the method/criteria utilized for lender inclusion on the list;
- The college will provide comparative information on borrower benefits offered by listed lenders;
- The college will advise students that the use of a preferred lender is not required and no unnecessary delays in loan certification will occur for borrowers who do not use a preferred lender.
Prohibition of lending institutions' staffing of college financial aid offices
- The college may not allow and shall ensure that no employee or other agent of a Lending Institution is ever identified to students or prospective students of the College or their parents as an employee or agent of the College.
Proper execution of master promissory notes
- If a college links or otherwise directs potential borrowers to any electronic Master Promissory Notes or other loan agreements, the college shall make available to students information on how to apply for other loans using a non-preferred lender.
School as lender
- If the College participates in the "School as Lender" program under 20 U.S.C. § 1085(d)(1)(E), the college may not treat School as Lender loans any differently than if the loans originated directly from another lender; all sections of the Code apply equally to such School as Lender loans as if the loans were provided by another lender.
Prohibition of opportunity loans
- As used herein, "override pools," "opportunity funds," and "opportunity loans" refer to any agreement, understanding or practice in which a lender applies more lenient loan underwriting criteria than it otherwise would to a certain class of loan applicants if the school meets certain milestones or metrics with respect to other loans with that lender, such as the number of loans initiated or in force, or the dollar amount of such loans.
- The college shall not arrange with a Lending Institution to participate in any override pools, opportunity funds, or opportunity loans, as defined above, if the participation in such program(s) prejudices any other borrower.
Adopted January 17, 2008