Financial Aid Code of Conduct
The Higher Education Opportunity Act helps schools that participate in the Title IV Federal Financial Aid Program develop, publish, administer and enforce a code of conduct that applies to the officers, employees and agents of the institution. It specifically highlights the following provisions:
Charleston School of Law as an institution and its individual officers, employees and agents shall not enter into any type of revenue-sharing arrangements with any lender.
No officer or employee of the Office of Financial Aid (or any employee or agent that has responsibilities with respect to educational loans or any of their family members) shall solicit or accept any gift from a lender, guarantor or servicer of education loans. A “gift” is defined as any gratuity, favor, discount, entertainment, hospitality, loan or other item having monetary value of more than a de minimus amount.
No officer or employee of the Office of Financial Aid (or any employee or agent that has responsibilities with respect to educational loans) shall accept from a lender, or an affiliate of any lender, any fee, payment or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
The Office of Financial Aid shall not steer borrowers to particular lenders or delay loan certifications. For any first-time borrower, the school shall not assign, through the award packaging or other methods, the borrower’s loan to a particular lender. In addition, the institution shall not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty agency.
Charleston School of Law and its agents shall not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of Title IV loans made, insured or guaranteed, a specified loan volume, or a preferred lender arrangement. An “opportunity pool loan” is defined as a private education 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.
Charleston School of Law shall not request or accept from any lender any assistance with call center staffing or Office of Financial Aid staffing.
No officer or employee of the Office of Financial Aid (or any employee or agent that has responsibilities with respect to educational loans) who serves on an advisory board, commission or group established by a lender or guarantor (or a group of lenders or guarantors) shall receive anything of value from the lender, guarantor, or group except for reimbursement for reasonable expenses incurred by the employee for serving on the board.