Anne Arundel Community College (AACC) employees are required to comply with the following code of conduct set by the Higher Education Opportunity Act with regard to participation in Title IV programs that prohibits conflict of interest for financial aid personnel and those who have responsibilities with respect to educational loans [HEOA § 487(a)(25)]. In compliance with federal law, AACC agrees to follow these specific policies [HEOA § 487(e)].
The Student Loan Code of Conduct applies to all employees who work in the AACC Financial Aid Office and all other AACC employees, including agents of the college, who have responsibilities related to educational loans or other forms of student financial aid. Items in this Code of Conduct provide additional standards of conduct for employees with responsibility for student financial aid and do not replace any existing or future requirements imposed by the State of Maryland or other AACC related codes of conduct, conflict of interest policies, ethics training, or other such requirements.
The Student Loan Code of Conduct also confirms that AACC does not have preferred lender arrangements of any kind or a preferred lender list.
AACC shall not enter into any revenue-sharing arrangements with any lender, guarantor or servicer. Revenue-sharing arrangement is defined by the Higher Education Opportunity Act of 2008, amending the Higher Education Act of 1965, Pub. L. # 110-315 (2008), (“HEOA”) as any arrangement between a college and a lender that results in the lender paying a fee or other benefits, including a share of its profits, to the college, or its officers, employees or agents, as a result of the college recommending the lender to its students or families of those students.
Financial Aid office employees are prohibited from soliciting or accepting 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. This 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 incurred.
A gift does not include:
No AACC officer, employee, or agent employed in the Financial Aid Office or otherwise responsible for education loans shall accept from any lender or its affiliate 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 or on behalf of a lender, guarantor, or servicer of education loans.
AACC participates in the William D. Ford Federal Direct Loan Program, which provides student and parent loans through the U.S. Department of Education.
AACC will not assign a borrower’s private student loan to a particular lender; all decisions will be made by the borrower in his/her independent review of borrower benefits and lender services. AACC will not refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
AACC will not request or accept from any lender any offer of funds to be used for private education loans (as defined in section 140 of the Truth in Lending Act), including funds for an opportunity pool loan to students in exchange for AACC providing concessions or promises regarding providing the lender with (i) a specified number of federal loans made, insured or guaranteed; (ii) a specified federal loan volume; or (iii) a preferred lender arrangement for such loans.
AACC will not request or accept from any lender, guarantor, or servicer of student loans any assistance with call center staffing or financial aid office staffing. 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 to assist the school with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, and other localized disasters and emergencies identified by the Secretary.
Employees of the Financial Aid Office serving on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, are 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.
All employees of the AACC Financial Aid office and any agents responsible for education loans are prohibited from having any conflicts of interest with respect to their responsibilities for Title IV education loans.
In addition to the items above, as a member of the National Association of Student Financial Assistance Administrators (NASFAA), AACC also follows the standards established in NASFAA’s Statement of Ethical Principles and Code of Conduct for Institutional Financial Assistance Professionals.