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Code of Conduct

Student Loan Code of Conduct

FINANCIAL AID SERVICES CODE OF CONDUCT

  • Never take any action for his or her personal gain or benefit.
  • Never take any action he or she believes is or might be contrary to law, regulation or the best interests of the students and parents we serve.
  • In every circumstance ensure information given to students and parents is accurate and unbiased and does not reflect any preference arising from actual or potential personal or institutional gain.
  • In every instance, be objective in making decisions and advising NCWC regarding institutions involved in any aspect of student financial assistance.
  • Never solicit or accept anything from an entity involved in the making, holding, consolidating or processing of any student loans, including anything of value, such as reimbursement of expenses for serving on an advisory board or as part of a training activity of or sponsored by any such entity.
  • Always disclose to the institution any involvement with or interest in any entity involved in any aspect of financial aid.

STUDENT LOAN CODE OF CONDUCT

PROHIBITION AGAINST REMUNERATION TO NCWC

  • NCWC will not solicit, accept or agree to accept anything of value from any lending institution, Guarantee Agency, or Servicer in exchange for any advantage or consideration provided by the lending institution related to its student loan activity.  This prohibition covers, but is not limited to:
    • Revenue Sharing Agreements
    • Any computer hardware for which NCWC pays below market prices
    • Any computer software used to manage loans unless the software can manage disbursements from all lenders
    • Any printing costs, postage or services
  • This does not prevent NCWC from soliciting, accepting or agreeing to favorable terms and conditions where the benefit is made directly to student borrowers.

PROHIBITION AGAINST REMUNERATION TO NCWC EMPLOYEES

  • NCWC will require and enforce that no officer, trustee, director, employee, or agent of the institution accept anything more than a nominal value on his or her own behalf or on behalf of others during any 12 month period from any lending institution, Guarantee Agency or Servicer.
  • This prohibition will include, but not be limited to a ban on any payment or reimbursement from any lending institution, Guarantee Agency or Servicer to institution employees for lodging, meals or travel to conferences or training seminars.
  • This does not preclude any officer, trustee, director, employee or agent of the institution from receiving compensation for conducting non-institution business with a lending institution, Guarantee Agency, or Servicer or from accepting compensation that is offered to the general public.
  • This prohibition does not prevent the institution from holding membership in any non-profit professional associations.

BAN ON GIFTS

  • No officer or employee involved in the affairs of the institution’s financial aid office shall solicit or accept any gift from a lender, guarantor, or servicer of education loans.
  • “Gifts” are defined as but not limited to:
    • Any type of gratuity, favor, discount, entertainment, hospitality, loan or other item having more than a token monetary value.  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 following items would not be considered to be “gifts”:

  • Standard material, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
  • Food, refreshments, training, or informal material furnished to any officer, trustee, director or institution employee, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such training contributes to the professional development of the officer, trustee, director or employee.
  • Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the institution if such terms, conditions, or benefits are comparable to those provided to all students of the institution.
  • Entrance and exit counseling services provided to borrowers to meet the institution’s responsibilities for entrance and exit counseling as required.”as long as”
    • The institution’s staff are in control of the counseling (and)
    • Such counseling does not promote the products or services of any specific lender
  • Philanthropic contributions that are unrelated to education loans or any contribution not made in exchange for any advantage related to education loans.
  • State education grants, scholarships, or financial aid funds administered by or on behalf of a State.

BAN ON GIFTS TO FAMILY MEMBERS

  • Gifts to family members of any officer, trustee, director or institution employee will be considered a gift to said officer, trustee, director or institution employee if:
    • The gift is given with the knowledge and acquiescence of the officer, trustee, director or institution employee (and)
    • The officer, trustee, director or institutional employee has reason to believe the gift was given because of the official position of said officer, trustee, director or institutional employee.

 LIMITS OF INSTITUTION EMPLOYEES PARTICIPATING ON LENDER ADVISORY BOARD

  • NCWC will require and enforce that no officer, trustee, director or employee of the institution  receive any remuneration for serving as a member or participant of an advisory board of any lending institution, Guarantee Agency or Servicer.
  • This does not preclude any officer, trustee, director or employee from participating on any lender advisory board that is unrelated to student loans.
  • This does not preclude any NCWC employee not involved in the affairs of the institution’s financial aid office from serving on the Board of Directors of a publicly traded or privately held company.

CONTRACTING ARRANGEMENTS PROHIBITED

  • Any officer, trustee, director or employee is prohibited from accepting any payments of any kind from a lender in exchange for any type of consulting services related to educational loans.
    • This does not prevent anyone else in the institution who has nothing to do with the student loans from entering into these agreements.
    • This does not prevent anyone not employed in the financial aid office who has “some” responsibility for student loans from entering into these arrangements if that individual in writing, recuses him or herself from any decision regarding educational loans.
    • This does not prevent anyone from serving on a Board of Directors or as trustee of an institution if the individual recuses him or herself from any decision regarding educational loans.

REVENUE SHARING AGREEMENTS PROHIBITED

  • NCWC will not enter any revenue sharing agreement where:
    • A lender provides or issues a loan that is made, insured, or guaranteed under this title to students attending the institution or to the families of such students; and
    • The institution recommends the lender and in exchange the lender pays a fee or provides other material benefits.

PROHIBITION ON OFFERS OF FUNDS FOR PRIVATE LOANS

NCWC will not request or accept any agreement or offer of funds for private loans in exchange for concessions or promises of:

  • A specified number of loans made, issued or guaranteed
  • A specific loan volume
  • A preferred lender arrangement

BAN ON STAFFING ASSISTANCE

  • NCWC will not request or accept from a lender any assistance with call center staffing or financial aid office staffing.
  • This does not include:
    • Professional development training for financial aid administrators
    • Educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials.
    • Staffing services on a short-term nonrecurring basis to assist the institution with financial aid-related functions during emergencies, including State-declared or federally-declared natural disasters.

INTERACTION WITH BORROWERS

  • NCWC participates in the FFELP loan program and all student and parent borrowers are packaged under that program:
    • NCWC will not assign, through award packaging or other methods, the borrower’s loan to a particular lender.
    • NCWC will not refuse to certify, or delay certification of any loan, based on the borrower’s selection of a particular lender or guarantee agency.

OPPORTUNITY POOL LOAN

  • NCWC will not request or accept from any lender any offer of funds to be used for private education loans (defined in section 140 of the Truth in Lending Act) including funds for an opportunity pool loan in exchange for NCWC providing concessions or promises regarding providing the lender with a specified number of loans made, insured or guaranteed; a specified loan volume of such loans; or a preferred lender arrangement for such loans.