Code of Conduct and Policy on Educational Loans
This policy establishes a code of conduct that reiterates and reflects Moberly Area Community College’s continuing commitment to conducting financial aid practices with integrity, free from conflicts of interest, in the interest of students, and in compliance with applicable law.
For purposes of this policy, certain key terms are defined as follows:
(a) any entity that itself or through an affiliate engages in the business of making loans to students, parents, or others for purposes of financing higher education expenses or that securitizes such loans; or
(b) any entity, or association of entities, that guarantees or services educational loans; or
(c) any industry, trade, or professional association that receives money from any entity described in subsections (a) and (b) above.
Preferred Lender Arrangement.
An arrangement or agreement between a Lending Institution and Moberly Area Community College,
(a) under which a Lending Institution provides or otherwise issues educational loans to the students attending Moberly Area Community College or the families of such students; and
(b) that relates to Moberly Area Community College or an affiliated organization recommending, promoting, or endorsing the educational loan products of the Lending Institution.
Revenue Sharing Arrangement.
Any arrangement between Moberly Area Community College and a Lending Institution that results in the Lending Institution paying a fee or other benefits, including a share of the profits, to Moberly Area Community College, its officers, employees, or agents as a result of Moberly Area Community College’s recommending the lender to its students or the families of those students.
Moberly Area Community College:
- Does not require the use of a particular Lending Institution or in any way limit the choice of Lending Institution.
- Does not recommend particular Lending Institutions to students or families of those students.
- Does not maintain a Preferred Lender list or have any Preferred Lender Arrangements.
- Processes loan applications through any Lending Institution a student or parent chooses.
- Does not assign for any borrower, through award packaging or other methods, a loan to a particular Lending Institution and does not refuse to certify or delay certification of any loan based on the borrower's selection of a particular Lending Institution.
- Prohibits conflicts of interest with respect to the loans.
- Prohibits Revenue Sharing Arrangements with any Lending Institution.
- Does not solicit or accept anything of value from any Lending Institution in exchange for any advantage sought by a Lending Institution to make educational loans to students enrolled at, or admitted to, Moberly Area Community College.
- Prohibits the solicitation or acceptance of any funds to be used for private educational loans in exchange for concessions by Moberly Area Community College to a Lending Institution.
- Prohibits any employee of the Financial Aid Office, or any employee who otherwise has responsibilities with respect to educational loans, from soliciting or accepting from a Lending Institution any gift worth more than a nominal value.
- Prohibits any employee of the Financial Aid Office, or any employee who otherwise has responsibilities with respect to educational loans, from entering into any type of consulting arrangement or other contract to provide to a Lender Institution services relating to educational loans.
- Prohibits employees of the Financial Aid Office, or any employee who otherwise has responsibilities with respect to educational loans, who serve on an advisory board (or commission or group) relating to educational loans established by a Lending Institution or group of Lending Institutions from receiving anything of value from the Lending Institution or group of Lending Institutions in connection with serving on such an advisory board (or commission or group).
- Prohibits external Lending Institutions' employees, representatives, or agents from providing staffing services to the Financial Aid Office.
- Prohibits external Lending Institution's employees, representatives, or agents from identifying themselves to students of Moberly Area Community College or their parents as employees, representatives, or agents of the Financial Aid Office.