|
|
Title IV Loan School Code of Conduct
As an institution that participates in Title IV loan
programs, the Institute of Hair Design (IHD) is adopting a code of
conduct which prohibits a conflict of interest with the responsibilities
of an officer, employee, or agent of the institution with respect to
such loans. IHD will publish the code of conduct on the institution’s
web site, and administer and enforce it. At a minimum, IHD employees who
work in administering, handling, or disbursing Title IV loans are to
abide by this code of conduct.
The subject of the code of conduct requirements is
generally an "officer or employee of the institution who is employed in
the financial aid office of the institution or who otherwise has
responsibilities with respect to education loans, or agent who has
responsibilities with respect to education loans." The code includes the
following:
 | a ban on revenue-sharing arrangements |
| a ban on gifts from a lender, guarantor, or
servicer of loans to any officer, employee in the financial aid
office, or agent with responsibility for loans, except for
 | material or programs related to loans,
default aversion, etc. |
| food, refreshments, training, or
informational material furnished as an integral part of a
training program |
| favorable terms, conditions on a loan
provided to a student-employee, if the benefits are comparable
to those provided to all students |
| entrance and exit counseling services, as
long as institutional staff maintain control and the products
and services of any lender are not promoted |
| philanthropic contributions to an institution
that are unrelated to education loans and not made in exchange
for any advantage related to education loans |
|
| a prohibition on contracting or consulting
arrangements except that
| an employee or officer who is not employed in
the financial aid office and does not have responsibilities for
loans may perform paid or unpaid service on a board of directors
of a lender, guarantor or servicer |
| an employee or officer who is not employed in
the financial aid office but does have responsibilities for
loans may perform paid or unpaid service on a board of directors
of a lender, guarantor or servicer if the institution has a
conflict of interest policy that requires them to recuse
themselves from decisions regarding the institution |
| an officer or employee of a lender,
guarantor, or servicer may serve on a board of directors of an
institution if the institution’s conflict of interest policy
requires them to recuse themselves from decisions regarding
student lending |
|
| ensure that the institution does not assign a
first-time borrower’s loan to a particular lender, or refuse to
certify, or delay certification of any loan based on the borrower’s
selection of a lender |
| prohibition on asking for or accepting any offer
of funds to be used for private educational loans or opportunity
pool loans in exchange for providing a lender with loan volume or a
preferred lender arrangement |
| a ban on requesting or accepting staffing
assistance from a lender, except for
| professional development training |
| educational counseling, financial literacy,
or debt management materials |
| short-term staffing assistance to help the
institution during emergencies |
|
| a prohibition on payment, except for
reimbursement for reasonable expenses, by lenders or guarantors to
financial aid office employees or others with responsibilities for
education loans. |
IHD employees are bound by this Code of Conduct.
|
