Student Loan Code of Conduct


Prohibition against remuneration to Central Carolina Technical College (CCTC)
CCTC will not solicit, accept or agree to accept anything from any Lending Institution, Guarantee Agency or Servicer in exchange for any advantage or consideration provided by the Lending Intuition related to its student loan activity.

Prohibition against remuneration to CCTC Employees
CCTC will require and enforce that no officer, trustee, director, employee or agent of the college will accept anything more than a nominal value on his or her behalf or on behalf of another from, or on behalf of a Lending Institution, Guarantee Agency or Servicer.

  • This prohibition will include, but not be limited to a ban on any payment or reimbursement from any Lending Institution, Guarantee Agency or Servicer to College employees for lodging, meal, or travel to conferences or training seminars.
  • This prohibition does not prevent the college from holding membership in any non-profit professional associations.

Ban on Gifts
No CCTC employee shall solicit or accept any gift from a lender, guarantor, or servicer of educational loans.

"Gifts" are defined as but not limited to:

  • Any type of gratuity, favor, discount, entertainment, hospitality, loan, or other item having more than a token ($10.00) monetary value. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.
  • The following items would not be considered to be "Gifts":
    • Standard material, activities or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
    • Food, refreshments, training, or informational material furnished to any officer, trustee, director or college employee, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such training contributes to the professional development of the officer, trustee, director or employee.
    • Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the institution if such terms, conditions, or benefits are comparable to those provided to all students of the institution.
    • Philanthropic contributions that are unrelated to education loans or any contribution not made in exchange for any advantage related to education loans.
    • State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
    • Entrance and exit counseling services provided to borrowers to meet the institution's responsibilities for entrance and exit counseling as required..."as long as":
      • The institution's staff are in control of the counseling (and)
      • Such counseling does not promote the products or services of any specific lender.

Ban on gifts to family members
Gifts to family members of any officer, trustee, director, or college employee will be considered a gift to any said officer, trustee, director, or college employee if:

  • The gift is given with the knowledge and acquiescence of the officer, trustee, director or university employee or
  • The officer, trustee, director, or college employee has reason to believe that the gift was given because of the official position of said officer, trustee, director, or university employee

Limits of college employees participating on lender advisory boards
CCTC will require and enforce that no officer, trustee, director or employee of the college will receive any remuneration for serving as a member or participant of an advisory board of any Lending Institution, Guarantee Agency or Servicer or receive any reimbursement of expenses from said participation.

  • This does not preclude any officer, trustee, director or employee from participating on any lender advisory board.

Contracting arrangements prohibited
Any officer, trustee, director or employee is prohibited from accepting any payments of any kind from a lender in exchange for any type of consulting services related to educational loans.

Revenue sharing agreements prohibited
CCTC will not enter any revenue sharing agreement where:

  • a lender provides or issues a loan that is made, insured, or guaranteed under this title to students attending the institution, or to the families of such students; and
  • CCTC recommends the lender and in exchange the lender pays a fee or provides other material benefits

Prohibition on offers of funds for private loans
CCTC will not request or accept any agreement or offer of funds for private loans in exchange for concessions or promises of a specified:

  • number of loans made, ensured or guaranteed
  • loan volume
  • preferred lender arrangement

Ban on staffing assistance
CCTC will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. This does not include:

  • Professional development training for financial aid administrators.
  • Educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials.
  • Staffing services on a short-term, nonrecurring basis to assist the institution with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters.

Interaction with borrowers
CCTC participates in the Federal Family Educational Loan Program (FFELP) and all student and parent borrowers are certified under that program. In respect to alternative loans:

  • CCTC will not, for any first-time borrower, assign, through award packaging or other methods, the borrower's loan to a particular lender.
  • CCTC will not refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.

Definitions

  1. "Employee" means any employee, agent, student financial aid contractor, director, officer or trustee of CCTC. For purposes of the code provisions relating to gifts, this term includes family members of the employee living in the same house.
  2. "CCTC" means all campuses, sites, departments or other components of Central Carolina Technical College.
  3. "Lender" means any entity involved in making, holding, consolidating, processing, originating, servicing, or guaranteeing any loan to students or parents to finance higher education expenses. This includes lenders who provide private educational loans as well as lenders who provide loans that are made, insured or guaranteed by the U.S. Department of Education.

© 2014 Central Carolina Technical College

Date/Time Published:9/1/2014 2:06