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The 2008 Higher Education Opportunity Act (HEOA)
conditions the eligibility of educational institutions to participate in
Title IV programs on the development, advertisement, administration and
enforcement of a Code of Conduct prohibiting conflicts of interest for the
institutions officers, employees and agents [HEOA § 487(a)(25)].
To comply with this
requirement, Grossmont College has developed the following Code of Conduct
(which was adapted from the GEN-08-12 Dear Colleague Letter and from
NASFAA's Statement of Ethical Principals and Code of Conduct for
Institutional Financial Aid Professionals):
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An officer or employee of the Grossmont
College Financial Aid Office shall take no action which may result in
their personal benefit and shall refrain from taking any action which
they believe is contrary to law, regulation, or the best interests of
the students and parents they serve.
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An officer or employee of the Grossmont
College Financial Aid Office shall make every effort to ensure that the
information and advice they provide is accurate, unbiased, and does not
reflect any preference arising from actual or potential personal gain.
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Neither Grossmont College as an
institution, nor any individual officer, employee or agent shall enter
into any revenue-sharing arrangements with any lender. The HEOA defines
a “revenue-sharing arrangement” as any arrangement between an
institution and a lender under which the lender makes Title IV loans to
students attending the institution (or to the families of those
students), the institution 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
institution or to its officers, employees, or agents.
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No officer or employee of Grossmont College
who is employed in the financial aid office or who otherwise has
responsibilities with respect to education loans, or agent who has
responsibilities with respect to education loans, shall solicit or
accept any gift from a lender, guarantor, or servicer of education
loans. For purposes of this prohibition, the term "gift" means any
gratuity, favor, discount, entertainment, hospitality, loan, or other
item having a monetary value of more than a de minimus amount. A gift
does not include (1) a brochure, workshop, or training using standard
materials relating to a loan, default aversion, or financial literacy;
(2) food, training, or informational material provided as part of a
training session designed to improve the service of a lender, guarantor,
or servicer if the training contributes to the professional development
of the institution’s officer, employee or agent; (3) favorable terms and
benefits on an education loan provided to a student employed by the
institution if those terms and benefits are comparable to those provided
to all students at the institution; (4) entrance and exit counseling as
long as the institution’s staff are in control of the counseling and the
counseling does not promote the services of a specific lender; (5)
philanthropic contributions from a lender, guarantor, or servicer that
are unrelated to education loans or any contribution that is not made in
exchange for advantage related to education loans, and; (6) State
education grants, scholarships, or financial aid funds administered by
or on behalf of a State.
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An officer or employee of Grossmont College
who is employed in the financial aid office or who otherwise has
responsibilities with respect to education 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 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 loans.
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Grossmont College
shall not request or
accept from any lender, any assistance with call center staffing or
financial aid office staffing, except that a lender may provide
professional development training, educational counseling materials (as
long as the materials identify the lender that assisted in preparing the
materials), or staffing services on a short-term, nonrecurring basis
during emergencies or disasters.
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Any
employee who is
employed in the financial aid office, or who otherwise has
responsibilities with respect to education loans or other student
financial aid, and who serves on an advisory board, commission, or group
established by a lender, guarantor, or group of lenders or guarantors,
shall be prohibited from receiving anything of value from the lender,
guarantor, or group of lenders or guarantors, except that the employee
may be reimbursed for reasonable expenses incurred in serving on such
advisory board, commission, or group.
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Grossmont College
shall not:
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for any first-time
borrower, assign, through award packaging or other methods, the
borrower's loan to a particular lender;
or
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refuse
to certify, or delay
certification of, any loan based solely on the borrower's selection of a
particular lender or guaranty agency.
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Grossmont College
shall not request or
accept from any lender any offer of funds to be used for private
education loans, including funds for an opportunity pool loan (an
“opportunity pool loan” is defined as a private educational loan made by
a lender to a student, or the student’s family, that involves a payment
by the institution to the lender for extending credit to the student),
to students in exchange for the institution providing concessions or
promises regarding providing the lender with:
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a
specified number of
loans made, insured, or guaranteed under Title IV;
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a
specified loan volume
of such loans;
or
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a
preferred lender
arrangement for such loans.
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