Code of Conduct for Educational Loans

College of Wilmington upholds the highest standards in ethics and conduct. The College participates in the William D. Ford Federal Direct Loan Program, which includes the Direct Subsidized and Direct Unsubsidized Student Loans, and the Direct Parent PLUS Loans. To comply with the 2008 Higher Education Opportunity Act (the “Act”), the College adopts the following Code of Conduct to provide guidance to employees in ensuring the integrity of the student aid process and in ensuring ethical conduct of College employees in regard to student loan practices. This Code of Conduct is applicable to all employees and agents, and specifically, the College of Wilmington’s Financial Aid Administration. The Financial Aid Administration was responsible for updating this Code of Conduct in July 2015 to ensure that:

Revenue Sharing
The College and its employees will not enter into any type of revenue-sharing arrangement with any lender, guarantor, or servicer. All loans are processed without regard to lender or mode of transmission (i.e., electronic or paper). The College will neither recommend a lender nor accept material benefits including revenue or profit sharing to the College, an officer, or an employee of the College or an agent.
The term “revenue-sharing arrangement” means an arrangement between an institution and a lender that – (i) a lender provides or issues a loan that is made, insured, or guaranteed to students under the Act attending the institution or to the families of such students; and (ii) 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, an officer or employee of the institution.

Financial Aid Employees are prohibited from soliciting or accepting any gift from a lender, guarantor, or servicer of education loans. Gifts include any gratuity, favor, discount, entertainment, hospitality, loan or other similar item having a monetary value of more than $50.00 (fifty dollars). 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. However, gifts do not include those specific exemption set forth in the Act (20 U.S.C. Section 1094(e)(2)(B)(ii)).b. Gifts to family members of a college employee are considered to be a gift to the employee if the gift is given with the knowledge and consent of the employee and there is reason to believe the gift was given because of the official position of that employee.

Contracting Arrangements
Financial Aid Employees shall not accept from any lender, or affiliate of any lender, any fee, payment, or other financial benefit (including opportunity to purchase stock) as compensation for any consulting arrangement or other contract to provide services to a lender, or on behalf of a lender, relating to education loans.

Preferred Lender Status
If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be fully and publically disclosed. Borrowers will not be auto-assigned to any particular lender.

Interaction with Borrowers
A borrower’s choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution, even if that lender is not included on the institution’s preferred lender list.

Staffing Assistance
College of Wilmington 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. The College will also prohibit employees, representatives, or agents of any lender, guarantor, or servicer of student’s loans from identifying themselves to students of the College or their parents as employees, representatives, or agents of the College.

Advisory Board Compensation
Financial Aid Employees and Employees who serve 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. Any employee who serves on such an advisory board, commission or group described above shall recuse himself or herself from any discussions regarding the College’s financial aid operations.

Use of Mascot, Logo, or Name by Lenders
No lender, guarantor, or group of lenders or guarantors, shall be permitted to use the name, emblem, mascot, or logo of College of Wilmington, or other words, pictures, or symbols readily identified with or marks of College of Wilmington in the marketing of private educational loans to the students attending College of Wilmington in any way that implies that College of Wilmington endorses the private educational loans offered by the lender, guarantor, or group of lenders or guarantors.

Conflict of Interest
Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the college has a business relationship.

Information Location
All required consumer information is displayed in a prominent location on the college web site(s) and in any printed materials, easily identified and found, and labeled as “Student’s Right to Know.”

Award Notification
Institutional award notifications and/or other institutionally provided materials shall include the following:
A breakdown of individual components of the college’s Cost of Attendance, designating all potential billable charges.
Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.
Standard terminology and definitions
Renewal requirements for each award.
In addition to the above, Financial Aid Employees shall comply with all other applicable federal, state, and local laws and regulations, as well as the College’s policies and procedures. Information provided by the Financial Aid Employees is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.