Policy:  Financial Aid Office Code of Conduct
Responsible Unit: Student Affairs
Category: Financial Aid  Office of Origin:  Financial Aid Policy Contact by Title: Director of Business Services
Created Date:   1.19.2021 Effective Date:  1.19.2021 Revised Date(s): 
Compliance:  HEA Sec. 485(a)(1)(F), 34CFR 668.41(d)(2)-(4), FSA Handbook Vol.2, Chpt 6, FSA Handbook Appendix F
Scope:  Financial Aid Office Staff
Approving Body (ies) and Date(s) (approved by each):  TCC Board of Directors 1.19.21
Policy Statement 
In accordance with the Higher Education Opportunity Act (HEOA), institutions of higher learning are to develop and comply with a code of conduct with regards to the administration of educational student loans. The purpose of this code is to prohibit conflict of interest between the makers of these loans and personnel of the College. The College’s primary commitment with respect to student loans is to ensure that borrower benefits and services are in the best interest of the student and parent borrowers.

The following provisions will serve as a guide in meeting this requirement:

1.  The College is prohibited from entering into any revenue sharing arrangement with any lender. Revenue sharing arrangement is defined as an arrangement between a covered institution and a lender under which:
  • A lender provides or issues educational student loans to students or families of such students attending the institution; and The institution recommends the lender or loan product of the lender
  • and, in exchange, the lender pays a fee or provides other material benefits, including revenue or profit sharing, to the institution.
2.  Employees of the financial aid office or others who otherwise have responsibilities with respect to educational student loans must not solicit or accepts gifts from a lender, guarantor, or a loan service provider. The term gift means any gratuity, favor, discount, entertainment, loan, or other item having a monetary value 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 an expense is incurred.

3.  Financial Aid personnel or other College personnel who are otherwise responsible with respect to educational student loans must not accept from any lender or affiliate of any lender any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender for or on behalf of a lender relating to educational student loans.

4.  The College will not assign, through award packaging or other methods, lenders to any first time borrower; or refuse to certify or delay the certification of any loan based on the borrower’s selection of a particular lender or guaranty agency.

5.  The College will not request or accept from any lender any offer of funds to be used for private education loans to students in exchange for the institution providing concessions or promises regarding providing the lender with:
  • A specific number of educational student loans;
  • A specific loan volume for such lender; or
  • A preferred lender arrangement for such loans.
6.  The College will not request or accept from any lender any assistance with financial aid office staffing.

7.  Any College financial aid office personnel or anyone else who has educational student loan responsibilities who serves on an advisory board for a lender or guarantor will not receive anything of value from the lender or guarantor except reimbursement for reasonable expenses incurred while serving on such advisory board, commission or group.

Related Documents 

Conflict of Interest and Ethical Practices Policy
Student Rights and Responsibilities - Financial Aid