Code of Conduct
Revenue-Sharing Arrangements: St. Louis Community College will not enter into a revenue sharing arrangement with any lender. The College will not enter into an arrangement with a Title IV lender where the lender pays a fee or provides other material benefits to the school or its officers, employees or agents in exchange for the College recommending the lender to its students.
Gifts: Any College officer, employee or agent with responsibilities with respect to education loans for financial aid is prohibited from requesting or receiving gifts from lenders, guarantors or loan servicers. A gift is any item or service having a monetary value for more than a de minimus amount.
Exceptions include the following:
- Materials or services related to loan issues, default aversion and prevention, or financial literacy;
- Expenses integrally related to training designed to improve service to the school and contribute to professional development;
- Favorable loan conditions provided to students employed by the College if the same conditions are provided to all other students at the school;
- Entrance and exit counseling services that are controlled by College staff and that do not promote a specific lender;
- Contributions from a lender, guarantor or servicer made to the College that are philanthropic, unrelated to education loans are not made in exchange for an advantage related to education loans;
- Education grants, scholarships or financial aid administered by or on behalf of a State.
Gifts to Family Members: Gifts to family members and others with relationships to employees, officers, and agents will be considered gifts to said employees, officers and agents if they know about the gift and believe the gift was based on the position of the employee, officer or agent.
Contracting Arrangements: A College officer, employee or agent with responsibilities with respect to education loans or financial aid is prohibited from receiving financial benefit from a lender or lender affiliate as compensation for any consulting or services provided to or for a lender.
Interaction with Borrowers: The College will not assign a loan from a first-time borrower to a particular lender or delay or refuse to certify a loan based on the borrower’s choice of lender or guarantor.
Offers of Funds for Private Loans: The College will not request or receive an offer of funds from a lender for private education loans including funds for opportunity pool loans to its students in exchange for concessions or promises to the lender regarding the number or volume of Title IV loans made by said lender or a preferred lender status for such loans.
Staffing Assistance: The College will not request or accept assistance from a lender for call center or financial aid office staffing. A school can receive assistance for FAA training, lender identified education materials for borrowers, and short-term non-recurring staffing assistance during emergencies.
Advisory Board Compensation: Any College employee with responsibilities with respect to education loans for financial aid who serves on an advisory group established by a lender, guarantor or group of lenders or guarantors may only receive reimbursement for reasonable expenses related to serving in the group.