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 § 487(a)(25)]. Any 最佳亚洲体育博彩平台圣十字 officer, 员工, or 代理 who has responsibilities with respect to student educational 贷款s must comply with this code of conduct.

The obligations in this Code of Conduct are in addition to any requirements imposed by state ethic laws, 联邦法律, or 最佳亚洲体育博彩平台圣十字 policies, i.e., the stricter standard of ethical behavior will apply in all instances.

1. 最佳亚洲体育博彩平台圣十字 and its affiliates have no preferred lending agreement with any lender of private educational 贷款s and as such no officer or 员工 of the institution shall engage in the practice of recommending, 促进, or endorsing private education 贷款s for students attending the institution.
2. Neither 最佳亚洲体育博彩平台圣十字 as an institution nor any individual officer, 员工, 代理, or affiliate 员工 shall enter into any revenue-sharing arrangements with any lender.

Revenue-sharing arrangement includes circumstances where an institution recommends a lender or the 贷款 products of a lender who provides or issues a 贷款 in exchange for a fee or provision of material benefits, including revenue or profit-sharing, 致机构, or 员工 or 代理 of the institution.

1. No officer or 员工 of 最佳亚洲体育博彩平台圣十字 who is employed in the Financial Aid office or who otherwise has responsibilities with respect to education 贷款s, or 代理 who has responsibilities with respect to education 贷款s, 或者他们的家人, shall solicit or accept any gift from a lender, 担保人, 或教育贷款服务商.

For purposes of this prohibition, the term “gift” means any gratuity, 忙, 折扣, 娱乐, 热情好客, 贷款, or other item having a monetary value of more than a de minimum amount. (The term includes a gift of services, 运输, 住宿, 或者吃饭, 是否以实物提供, 通过购买门票, 预付款, or reimbursement after the expense has been incurred.)

1. An officer or 员工 of 最佳亚洲体育博彩平台圣十字 who is employed in the Financial Aid office or who otherwise has responsibilities with respect to education 贷款s, or an 代理 who has responsibilities with respect to education 贷款s, shall not accept from any lender or affiliate of any lender any fee, 付款, 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 education 贷款s.
2. 最佳亚洲体育博彩平台圣十字 shall not:
   • 任何首次借款者, 分配, through award packaging or other methods, the borrower’s 贷款 to a particular lender, or
   • 拒绝证明, 或者延迟认证, any 贷款 based on the borrower’s selection of a particular lender or guaranty agency.
3. 最佳亚洲体育博彩平台圣十字 shall not request or accept from any lender any offer of funds to be used for private education 贷款s, including funds for an opportunity pool 贷款, to students in exchange for the institution providing concessions or promises regarding providing the lender with respect to:
   • a specified number of private 贷款s,
   • a specified 贷款 volume of such 贷款s, or
   • a preferred lender arrangement for such 贷款s.

Opportunity pool 贷款 means a private education 贷款 made by a lender to a student attending the institution or the family member of such a student that involves a 付款, 直接或间接, 通过这样的点数制度, 保费, 额外的利益, or financial support to such lender for the purpose of such lender extending credit to the student or the family.

1. 最佳亚洲体育博彩平台圣十字 shall not request or accept from any lender any assistance with Financial Aid call center staffing or Financial Aid Office staffing.
2. Any 最佳亚洲体育博彩平台圣十字 员工 who is employed in the Financial Aid Office, or who otherwise has responsibilities with respect to education 贷款s or other student financial aid, and who serves on an advisory board, 委员会, 或由出借人成立的集团, 担保人, or group of lenders or 担保人s, shall be prohibited from receiving anything of value from the lender, 担保人, or group of lenders or 担保人s, except that the 员工 may be reimbursed for reasonable expenses incurred in the serving on such advisory board, 委员会, or group consistent with applicable 最佳亚洲体育博彩平台圣十字 policies.

Any and all reimbursements received for any service on advisory boards, 佣金, 或者其他贷款机构, servicers or 担保人s must be reported annually to the Department of Education.