Code of conduct
Universities that participate in Title IV loan programs must adopt a code of conduct with respect to such loans with which the university's officers, employees, and agents must comply. This code of conduct prohibits a conflict of interest between the responsibilities of an officer, employee, or agent of the university and financial institutions with respect to such loans and includes the following provisions:
The University of the South shall not enter into a revenue-sharing arrangement
A revenue-sharing arrangement is defined as an arrangement between a university and a lender under which the lender pays a fee or provides other material benefits, including revenue or profit sharing to the university, or an employee or agent of the university and in exchange, the university recommends the lender or distributes the lender's loan products and the lender makes Title IV loans to the students and parents of the students attending the university.
The University of the South is prohibited from soliciting or accepting any gift from any lender, guarantor, or servicer of education loans
A gift is defined as gratuity, entertainment, loan hospitality, discount, lodging, meals, favor, or any other item having monetary value more than the minimum amount. However, the university is not prohibited from accepting certain items and services that are specifically exempt from the definition of gift such as:
- Materials, activities, or programs related to a lender's workshop or training
- Food, refreshments, training, and/or informational material given to the university for a training session designated to improve the service of the lender, guarantor, or servicer of education loans, only if such training promotes professional development of the university's staff
- Entrance or exit counseling as long as the university's employees are conducting the counseling and the counseling does not favor any particular lender
- Philanthropic contributions to the university from a lender, servicer, or guarantor that are a separate entity from education loans
- State granted scholarships or financial aid
Also, a gift to a family member of the university's employee shall be considered a gift if the employee was aware of the gift and believed it was given to the family member on behalf of the employee's position at the university.
The University of the South is prohibited from making certain contracting arrangements
The university's employees with education loan responsibilities will not accept any financial benefits, including the opportunity to attain stock, from any lender for compensation for any type of arrangement or contract to provide services to a lender or on behalf of a lender.
Exceptions to the rule are:
- An employee of a university who is not employed in the university's financial aid sector and does not have any educational loan responsibilities may perform paid or unpaid services to the Board of Directors of a lender, guarantor, or servicer of education loans.
- An employee of the university who has responsibilities with education loans may perform paid or unpaid service on a Board of Directors of a lender, guarantor, or servicer of education loans, only if the university has a written conflict of interest policy that states the employee must disqualify themselves from taking part in any decision of the Board regarding education loans at the university.
- An employee or representative of the university may serve on a board of directors, or as a trustee of a university, if the university has a written conflict of interest policy that states the board member or trustee must disqualify themselves from taking part in any decision regarding education loans at the university.
The University of the South prohibits offers of funds for private loans
The university shall not request or accept funds from any lender for private education loans including funds for an opportunity pool loan to its students in exchange for the university providing concessions or promises to the lender regarding the number or volume of Title IV loans or a preferred lender arrangement.
For any first-time borrower, the University of the South will 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 particular lender or guarantor.
The University of the South will not request or accept any assistance from any lender with call center or financial aid office staffing
Professional development training for financial aid administrators, educational counseling/financial literacy/debt management materials for borrowers that disclose the identification of the lender that assisted in preparing and providing the materials, or staffing services on a short-term, non-recurring basis during State or federally declared natural disasters, federally declared natural disasters, and other localized disasters and emergencies identified by the Department of Education are not prohibited.
Any university employee, in the financial aid office or with responsibilities regarding education loans or financial aid, who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors shall be prohibited from receiving anything of value from the lender, guarantors, or group of lenders or guarantors. However, the employee may be reimbursed for reasonable expenses incurred in serving on the advisory board, commission, or group.
