Code of Conduct Regarding Lender Relationships & Loans
I. ETHICAL PRINCIPLES:
All decisions and actions made or taken by any of TSHAS’s financial aid office associates or any other officers and associates who have contact with guaranty agencies or lenders shall be consistent with the following principles:
- STUDENT CHOICE: TSHAS participates in the Federal Student Aid program, under which all federal loans are processed through the Direct Lending program run by the US Department of Education. Students will be given a genuine, fair and equal opportunity to choose among and between all private loans lenders, and student choice will not be limited to those lenders or loans made available or recommended by TSHAS.
- STUDENT INTERESTS: TSHAS will seek to establish relationships with those lenders which offer the best benefits for students – interest rates and fees, payment terms and services.
- STUDENT PRIVACY: All student financial information – about need, resources, loans and other aid – will be kept confidential and, without written student authorization, not shared with outside parties, other than the United States Department of Education (DOE), state aid agencies, lenders, servicers and guaranty agencies. Any such release will be made pursuant to FERPA regulations.
- CODE OF CONDUCT: All directors, officers, associates and other representatives of TSHAS (“TSHAS Representatives”) are required to comply with each of the following rules in this Code of Conduct for Lender Relationships & Loans (“Code”) and to also promptly inform either the TSHAS’s legal counsel or president (as directed by the TSHAS in writing) if they become aware of facts indicating that there may have been a violation of the Code:
II. PROHIBITED RELATIONSHIPS:
a) No TSHAS Representative shall act as a officer, associate, consultant or sales representative for any guaranty agency or lender, no financial aid officer or associate of TSHAS (including any officer of TSHAS with responsibility for overseeing the financial aid office and/or TSHAS’s relationships with lenders) shall serve on the board of directors of a lender, and no other associate, officer and director of TSHAS shall serve as an uncompensated member of the board of directors of any lender, unless such individual has confirmed in writing that he/she will abide by TSHAS’s published conflict of interest policy and has obtained written permission from legal counsel or president of TSHAS.
III. LOAN PROCESSING ARRANGEMENTS:
- a) TSHAS will not use any software or processing system or practices that create a ‘default’ arrangement through which a student borrower is automatically referred to any one or more private student lenders, whether or not any such lenders have been designated by TSHAS as “preferred lenders.”
- b) TSHAS will not use any financial aid processing or packaging practices that delay certification of borrowers choosing private student loan lenders not on the Lender List.
IV. LENDER COMPARISONS: If the Institution provides students with information on loans from private lenders, it will provide each student with a separate written reminder of the potential availability of federal student loans and a written comparison of the principal terms of such loans to the principal terms of federal student loans, including eligibility conditions, interest rates, origination fees, and repayment options & terms.