Employee Code of Conduct*
Officers, employees, and agents of the institution are expected to
always maintain exemplary standards of professional conduct in all
aspects of carrying out his or her responsibilities, specifically
including all dealings with any entities involved in any manner in
student financial aid. As required by the Higher Education Opportunity
Act (HEOA) an institution participating in a Title IV loan program
must develop, publish, administer, and enforce the code of conduct.
The Code of Conduct applies to the officers, employees, and agents of
San Diego City College.
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.
Ban on employees of the
financial aid office receiving gifts from a lender, guaranty agency or
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 minimus amount.
Ban on contracting
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.
steering borrowers to particular lenders or delaying loan
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.
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.
Ban on staffing
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.
Ban on advisory board
Any employee of the institution’s 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.
*School Code of Conduct (COC) HEA 487(a)(25) & 487(e), DCL pg 69-71