CODE OF CONDUCT
Student Loan Program Code of Conduct
Trinity International University (TIU), as a participant in the William D. Ford Direct Loan Program (DL), and offering private educational loans to its students, has adopted a Code of Conduct, in compliance with sec 487(a) (25) of the HEA of 1985.
The goal of the TIU financial aid office is to provide the highest quality service in the most efficient and timely manner possible, while upholding the mission of the institution, and acting in a matter with the integrity of a Christian institution. We willingly adhere to the following ‘Code of Conduct.’ All officers, employees and agents of the TIU Financial Aid Office have read and willingly agreed to adhere to the Code of Conduct.
- TIU will not enter into a revenue-sharing agreement with any lender. A “revenue-sharing arrangement” is defined to mean any arrangement made between an institution and a lender under which the lender makes Title IV loans to students attending the institution (or to the families of those students), 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 or to its officers, employees or agents.
- TIU embraces a ban on the employees of the financial aid office receiving gifts from a lender, guaranty agency or loan servicer. No officer or employee of the TIU financial aid office, (or an employee or agent who otherwise has responsibilities with respect to educational loans) will solicit or accept 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 having monetary value of more than a de minimus amount. However, a gift does not include (a) a brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy, such as a brochure, workshop, or training; (b) food, training, or informational material provided as part of a training session designed to improve the service of a lender, guarantor, or servicer if the training contributes to the professional development of the institution’s officer, employee or agent; (c) favorable terms and benefits on an education loan provided to a student employed by the institution if those terms and benefits are comparable to those provided to all students at the institution; (d) entrance and exit counseling as long as the institution’s staff are in control of the counseling and the counseling does not promote the services of a specific lender; (e) philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans or any contribution that is not made in exchange or advantage related to education loans; (f) State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
- TIU embraces a ban on contracting agreements. No officer or employee of the TIU financial aid office (or employee or agent who otherwise has responsibilities with respect to education loans) will accept from a lender, or an affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
- TIU embraces a prohibition against steering borrowers to particular lenders or the delay of loan certifications. For the first time borrower, TIU will not assign, through the award packaging or other methods, the borrower’s loan to a particular lender. In addition, TIU will not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty agency.
- TIU embraces a prohibition on offers of funds for private loans. TIU will not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of Title IV loans made, insured, or guaranteed, a specific loan volume, or a preferred lender arrangement. An ‘opportunity pool loan’ is defined as a private education loan made by a lender to a student (or the student’s family) that involves a payment by the institution to the lender for extending credit to the student,
- TIU bans the use of staffing assistance from lenders. TIU will not request or accept from any lender any assistance with call center staffing or financial aid office staffing, except that provided by a lender that involves 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 during emergencies or disasters.
- TIU adopts a ban on advisory board compensation. An employee of the TIU financial aid office (or employee who otherwise has responsibilities with respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor, or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board.