Financial Aid Code of Conduct

Saddleback College participates in the Federal Direct Loan Program and does not offer private loans or participate in private or alternative loan programs.

The Higher Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid personnel. Accordingly, Saddleback College has created the following code of conduct.

The policy applies to all employees who work in the Financial Aid Office and all other school employees, officers, and agents who have responsibilities with respect to education loans.

  1. Ban on revenue-sharing arrangement with any lender. All employees are banned from participating in a “revenue-sharing arrangement” between the institution and lender under which the lender makes Title IV loans to students attending the institution.
  2. Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
  3. No amount of cash, gift, or benefit in excess of a de minimums amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family).
  4. Ban on employees of the financial aid office receiving gifts from a lender, guaranty agency or loan servicer. No financial aid officer or employee of the institution may 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 minimums amount.
  5. Ban on contracting arrangements. No officer or employee of the institution’s financial aid office may 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 service to or on behalf of a lender relating to education loans.
  6. Prohibition against steering borrowers to particular lenders or delaying loan certifications. For any first-time borrower, an employee of the institution’s financial aid office may not assign, through the award packaging or other methods, the borrower’s loan to a particular lender.
  7. Prohibition on offers of funds for private loans. The institution may 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 specified 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 that involves a payment by the institution to the lender for extending credit to the student.
  8. Ban on staffing assistance. The institution may not request or accept from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training, and educational counseling materials.
  9. Ban on advisory board compensation. Any employee of the institutions financial aid office who serves on an advisory board, commission, or group established by a lender or guarantor is prohibited from receiving anything of value from the lender, guarantor, or group.

*This Code of Conduct pertains to any alternative/private loans