Code of Conduct
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
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Grossmont College 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 solely on the borrower's selection
of a particular lender or guaranty agency.
- 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:
- a specified number of loans made, insured, or guaranteed under Title IV;
- a specified loan volume of such loans; or
- a preferred lender arrangement for such loans.