Code of Conduct for Educational Loans
The Higher Education Opportunity Act (HEOA) requires educational institutions to develop and comply with a code of conduct that prohibits conflicts of interest for financial aid personnel [HEOA Section 487 (a) (25)]. The purpose of this code of conduct is to ensure that a students’ best interests are always at the forefront of all decisions. Any Southern Careers Institute (“SCI”) officer, employee, or agent who has responsibilities with respect to student educational loans must comply with this code of conduct.
- Compliance with Applicable Laws and Regulations SCI has a policy to observe all laws, rules, and regulations of government regulatory agencies and authorities that oversee the school. This specifically includes requirements under the Higher Education Act, regulations of the U. S. Department of Education, the policies of the school’s accrediting agency, as well as other state, local and federal laws. If federal, state, or local law exists that are either contradictory or stricter than this policy, employees must apply the law.
- Conflict of Interest SCI strictly prohibits conflicts of interest between the school and lenders, servicers, or guaranty agencies.
- Employee or Officer Compensation Prohibition No employee or officer of SCI shall accept or solicit any gift from a lender, guarantor, or servicer of education loans other than of a nominal value. “Nominal value” means a total retail value of not more than ten dollars ($10.00) as calculated over a 12-month period. For purposes of this prohibition, the term “gift” means any gratuity, favor, discount, entertainment, hospitality, loan, or other item.
- Financial Relationship Prohibition An officer or employee of SCI who is employed in the financial aid office, or who otherwise has responsibilities with respect to educational loans or an agent who 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 buy 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 education loans. SCI prohibits employees, representatives, or agents of a lender from representing themselves as employees of the school to students or parents.
- Revenue Sharing SCI shall not engage in revenue sharing with any student loan lender. “Revenue sharing” means any arrangement between the school and a student loan lender under which the lender provides or issues loans to students attending the school or to the families of such students; and the school 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 school or its agent.
- Staffing Assistance from Lenders SCI shall not request or accept from any lender any assistance with call center or financial aid office staffing, including in-person school required initial or exit counseling, except as permitted by applicable federal student loan requirements.
- Prompt Certification of Loans from Any Lender SCI shall 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.
- Opportunity Loans SCI shall not request or accept from any lender any offer or funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for the institution providing concessions or promises regarding providing the lender with
- a specified number of private educational loans (non-Title IV loans) or loans made, insured, or guaranteed under Title IV.
- a specified loan volume of such loans; or c) a preferred lender arrangement for such loans. An “opportunity” loan means a student loan provided to borrowers with poor or no credit history, or who otherwise would not meet the student loan lender’s eligibility criteria.
- Lender Advisory Board Restrictions Any SCI employee or officer shall not accept any remuneration or reimbursement of expenses for serving as a member or otherwise participating on a student loan lender’s advisory board, commission, committee, or group established by a lender, guarantor, or group of lenders or guarantors, and shall be prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee or officer may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, committee, or group.
- Implementation SCI shall require all employees with direct responsibilities relating to student loans to obtain training regarding SCI Code of Conduct for Educational Loans, applicable federal and state student loan laws and regulations, and related school policies and procedures. SCI shall review its code of conduct with all employees who have direct responsibility relating to student loans by July 1st of each year or within 30 days of new requirements going into effect to ensure these employees maintain current knowledge of the code and applicable regulations. In addition, each year, SCI will review its policy and procedure as part of its compliance plan to ensure that the school is in full compliance with all regulations governing the school.
- Questions or Concerns If a student or employee has any concerns related to compliance with any of the requirements in the Code of Conduct for Educational Loans, please contact Chris McCool, Vice President, Financial Aid Operations [email protected]
During entrance counseling, financial aid staff explain how both federal student loans and the master promissory note works, emphasizes the importance of repaying all loans, describes the consequences of default, and shows borrowers monthly repayment amounts based on their program of study. Financial literacy is also discussed to help students better understand how to manage debt. Entrance counseling ensures students understand the terms and conditions of their loan and rights and responsibilities. Once completed, a record of completion will be sent to the school selected. https://studentaid,gov.entrance-counseling/
Exit counseling is the opportunity to clear up any misconceptions that students may have about their loan obligations. During the exit counseling process, completers are educated on how to understand and repay loans, avoid default, and make finances a priority. Thorough exit counseling is a cornerstone of the institution’s default prevention plan and is mandatory. Exit counseling must be completed when a student leaves school or drops below half-time enrollment. The purpose of exit counseling is to ensure students understand loan obligations and are prepared for repayment. https://studentaid.gov/exit-counseling/