Financial Aid Code of Conduct

Definitions

  1. "Employee" means any employee, agent, student financial aid contractor, director or officer of the School.
  2. "Lender" means any entity involved in making, holding, consolidating, originating, servicing or guaranteeing any loan to students or parents to finance higher education expenses.
  3. "Nominal value" means a total retail value of not more than ten dollars ($10.00) as calculated over a 12-month period, or as defined by a School policy consistent with applicable federal and state law. This paragraph shall not prohibit Employees from conducting non-student lending business with any Lender or accepting or soliciting anything of other than Nominal Value in any activity unrelated to student loans.
  4. "Revenue sharing" means any arrangement under which a Lender pays School, or an affiliated entity, a certain sum, fee, percentage or other material benefit calculated in relationship to the volume of loans received by the Lender from students of the School.
  5. "School" means Jones International University, its departments or other components of Jones International University adopting this Code of Conduct including associations under the institution's control and not separately incorporated.

Employee Compensation Prohibition

No Employee or family members living in the same household as the Employee or School-Affiliated Organization (as defined in 34 C.F.R. 682.200(b)(5)(i)(A)(8)) shall accept or solicit anything of other than Nominal Value from a Lender.

Financial Relationship Prohibition

  1. An Employee shall 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 or on behalf of a Lender relating to education loans.
  2. School Financial Aid Office Employees or people who otherwise have direct responsibilities with respect to educational loans or other financial aid shall:
    1. Avoid any equity or other interest in any student loan lender other than a remote interest (i.e. no more than 3% ownership interest or no more than 5% of total annual income in dividend payments); and
    2. Avoid consulting or similar financial relationships with Lenders and comply with the School policies concerning conflicts of interest.

Institutional Compensation Prohibition

The School shall not engage in Revenue Sharing and will not accept anything of value from a Lender in exchange for any advantage or consideration (including without limitation below market rates, preferential prices, access to other Lender products and services) provided to the Lender related to its education loan activity with the exception of accepting assistance as contemplated by 34 C.F.R. 682.200(b).

JIU does not charge a fee for completing any application for financial aid including the completion, certification or processing of a Direct Loan application.

Lender Advisory Board Restrictions

Consistent with applicable federal student loan requirements, an Employee shall not accept any remuneration or reimbursement of expenses for serving as a member of, or otherwise participating on, a Lender's advisory board or committee,

Preferred Lender List Requirements

  1. If the School decides to develop and/or publish any list of suggested, recommended or preferred Lenders, the school shall develop and maintain any such list based solely on the best interests of student and parent borrowers.
  2. The School shall prominently disclose on all publications of a list of preferred Lenders:
    1. The process and criteria by which the list was assembled;
    2. Comparative interest rate and benefit information; and
    3. Borrowers' right and ability to select alternative Lenders.
  3. The School will timely certify any loan from any Lender selected by the borrower that offers the loan, to the extent consistent with applicable federal student loan requirements. The School will not assign, through award packaging or other methods, the borrower's loan to a particular Lender, or refuse to certify or cause unnecessary certification delays for borrowers who use a Lender that has not been recommended or suggested by the School.
  4. The School shall ensure there are at least three Lenders named on each preferred lender list which are not "affiliates" of each other, as described in 34 C.F.R. § 682.212 (h)(3).
  5. The School shall rotate, randomize or list alphabetically any published preferred Lender list and review and update such lists at least once per year.
  6. The School shall inform borrowers that Lenders can, and do sell student loans and encourage borrowers to contact their Lenders for more information. The School shall require that all Lenders published on a preferred list commit in writing to disclose to the borrower before a loan agreement is signed whether there is an existing agreement to sell loans to another Lender and the contact information for the Lender who will be purchasing the borrower's loan. The School may remove a Lender from a published preferred Lender list if such Lender sells loans without ensuring that the advertised loan terms and benefits are honored with the new Lender.
  7. The School shall not include a Lender on a published preferred Lender list for one type of loan in exchange for benefits provided by the Lender with respect to a different type of loan.

Promotion of Preferred Lenders Prohibited

The School shall not allow a Lender it publishes on a preferred Lender list to use the name, emblem, mascot or logo of the School or other words, pictures, or symbols readily identified with the School in the marketing of private educational loans to the students attending the School that implies the School endorses the private educational loans offered by the Lender.

Master Promissory Notes

The School shall inform borrowers of the procedure(s) for completing a master promissory note or other loan agreement with the Lender of the borrower's choice, whether or not such Lender appears in preferred Lender list published by the School.

Lender Restriction Prohibition

The School shall not restrict borrowers to Lenders who process loans electronically or place other similar restrictions on borrowers.

Private Loans as a Last Resort

The School shall not certify student eligibility for a private educational loan without first: (1) informing the borrower that federal financial assistance (including grants and loans under Title IV) may be available and federal loans may provide more advantageous terms to the borrower than private loans; and (2) providing the Borrower other appropriate disclosure and obtaining the Student's consent to enter the institutional loan application process as an alternative to federal loans.

Opportunity Loans

  1. The School shall not enter into a student loan agreement with a Lender provided to borrowers with poor or no credit history, or who otherwise would not meet the Lender's eligibility criteria (an "Opportunity Loan") with a Lender under which the School provides concessions or promises to the Lender that prejudice other borrowers. The School shall not request or accept from any Lender any offer of funds to be used for private education loans to students in exchange for the School providing concessions or promises providing the Lender with a specified number of loans made, insured, or guaranteed; a specified loan volume of such loans; or a specified Lender arrangement for such loans.
  2. The School shall not certify student eligibility for an Opportunity Loan made available pursuant to an agreement between the School and a Lender unless: (a) the agreement includes the option of short term or partial loans not to exceed one year; and (b) the School informs the borrower of the short term or partial loan option, so the borrower can consider different or less expensive financing if the borrower's financial condition improves.

Staffing Assistance from Lenders

The School shall not request or accept from any Lender any assistance with staffing, including in person initial or exit counseling, except as permitted by applicable federal student loan requirements. The School shall ensure that any Lender employees on campus are accurately represented as such and not misidentified as Employees. While Lenders may provide professional development training to School's Financial Aid Administrators and participate in financial literacy outreach activities, Lender employees must refrain from promoting Lender products and clearly disclose the name of the entity preparing any written materials.

Implementation

  1. The School agrees to publish this Code of Conduct prominently on its website within sixty business days of its adoption by the School.
  2. The School shall require its Employees with direct responsibilities relating to student loans to obtain training concerning this Code of Conduct, related School policies and applicable federal and state student loan laws and regulations ("Applicable Law") within 90 days of School's adoption of this Code of Conduct or within 90 days of a new Employees date of hire. The School shall adopt procedures to ensure Employees maintain current knowledge of this Code of Conduct and Applicable Law.