The Higher Education Opportunity Act (HEOA) requires educational institutions to develop and comply with a code of conduct that prohibits conflicts of interest in student financial services. Any College for Creative Studies (CCS) officer, employee, or agent who has responsibilities with respect to student educational loans must comply with the code of conduct.
1. No action will be taken by CCS financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.
a. Employees within the CCS Financial Aid Office will not award aid t0 themselves or their immediate family members. Staff will reserve this task for the Director of Financial Aid or the Vice President for Enrollment and Student Services, to avoid the appearance of a conflict of interest.
b. No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family).
2. CCS does not assign for any borrower a particular lender, does not require the use of particular lenders or in any way limit the choice of educational loan lenders a student may borrow from. Education loan applications will be processed without unnecessary delay through any lender a student chooses.
3. CCS does not recommend external lenders. A list of education lenders utilized by previous borrowers is maintained for the convenience of students and parents but is not intended as an endorsement of any lender.
4. CCS does not solicit or accept anything of value from any lender in exchange for any advantage sought by the lender to make educational loans to students enrolled at, or admitted to, the College.
5. CCS will not request or accept from any lender an offer of funds for private loans to students, including funds for an opportunity pool loan, in exchange for a promise of a certain number of loans, a specified loan volume, or a preferred lender arrangement.
6. CCS will not enter into any revenue-sharing arrangement with any lender.
7. CCS prohibits employees, representatives or agents of external lenders from providing staffing services to the financial aid office.
8. CCS prohibits employees, representatives or agents of external lenders from identifying themselves to students of the College or their parents as employees, representatives or agents of the financial aid office.
9. CCS prohibits employees of the CCS financial aid office, or any employee who otherwise has responsibilities with respect to educational loans, from taking from any lender any gift worth more than nominal value.
10. CCS prohibits employees of the CCS financial aid office, or any employee who otherwise has responsibilities with respect to educational loans, from entering into any type of consulting arrangement or other contract to provide to a lender services related to educational loans.
11. CCS requires employees of the CCS financial aid office, or any employee who otherwise has responsibilities with respect to educational loans, who serve on an advisory board (or commission or group) related to educational loans established by a lender or group of lenders are required to report this service to the Director of Financial Aid or Vice President for Enrollment Services. Employees are prohibited from receiving anything of value from the lender or group of lenders in connection with serving on such advisory board (or commission or group).