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College Loan Code of Conduct

Prohibition on Revenue-Sharing Arrangements with Lenders

No officer or employee of the St. Joseph’s College of Nursing at St. Joseph’s Hospital Health Center (hereinafter the “College”) who has responsibilities for student lending will enter into any revenue-sharing agreement with any lender. For purposes of definition, revenue sharing arrangement means an agreement between the College and a lender under which:

  • a lender provides or issues a loan that is made, insured or guaranteed under Title IV to students attending the College or to the families of students attending the College; and
  • the College 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 College, an officer or employee of the College.

Prohibition on Gifts from Lenders, Guaranty Agencies and Loan Servicers

No officer or employee of the College who has responsibilities with respect to education loans shall solicit or accept any gift from a lender, guarantor or servicer of education loans. Gift means any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than a de minimus amount. The term includes a gift of services, transportation, lodging or meals, whether provided in kind, by purchase of a ticket, payment in advance or reimbursement after the expense has been incurred. The term “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 College’s officer, employee or agent;
  3. favorable terms and benefits on an education loan provided to a student employed by the College if those terms and benefits are comparable to those provided to all students at the College;
  4. entrance and exit counseling as long as the College’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 advantage related to education loans, and;
  6. state education grants, scholarships or financial aid funds administered by or on behalf of a state. For purposes of this paragraph, a gift to a family member of an officer, employee or any other individual based on that individual’s relationship with the officer or employee shall be considered a gift to the officer or employee, if the gift is given with the knowledge and acquiescence of the officer or employee and  the officer or employee has reason to believe the gift was given because of the official position of the officer or employee.

Consulting Arrangements with Lenders Prohibited

No officer or employee of the College’s Financial Aid Office or individual who otherwise has responsibilities with respect to education loans shall not accept from any lender or affiliate of any lender any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to educational loans.

Prohibition Against Steering Student Borrowers to Particular Lenders

The College will not:

  • for any first-time borrower, assign, through award packaging or other methods, the borrower’s loan to a particular lender; or
  • refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency

Prohibition of Offers of Funds for Private Loans

The College shall not request or accept from any lender any offer of funds to be used for private education loans, including funds for an opportunity pool loan to students in exchange for the College providing concessions or promises to the lender for:

  • a specified number of Title IV loans made, insured or guaranteed
  • a specified loan volume of such loans or
  • a preferred lender arrangement for such loans. 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 College to the lender for extending credit to the student.