Federal Direct Student Loans

The Financial Aid Office will publish this Student Loan Code of Conduct on its Consumer Information webpage and on its Federal Financial Aid webpage. The Financial Aid Office will administer and enforce this Code of Conduct and will require its employees and agents to be informed annually of its provisions.

For purposes of this code of conduct, Lending Institution means:

1. Any entity that itself or through an affiliate engages in the business of making loans to students, parents, or others for purposes of financing higher education expenses, or that securitizes such loans
2. Any entity, or association of entities, that guarantees or services education loans
3. Any industry, trade, or professional association that receives money from any entity described in items 1 or 2 above

FCC prohibits its employees from entering into any revenue-sharing arrangement with any lender, guarantor, or servicer. A revenue-sharing arrangement is one in which a lender provides loans to students or families attending FCC, and FCC recommends that lender or its loan products in exchange for a fee or other material benefit. FCC will not accept material benefits including revenue or profit sharing to the institution or to any officer, employee, or agent.

Employees of the Financial Aid Office are prohibited from soliciting or accepting any gift of more than a de minimis value from a lender, guarantor, or education loan servicer. Gifts include gratuities, favors, discounts, entertainment, hospitality, loans, transportation, lodging, meals, or services whether provided in kind, by ticket, payment in advance, or reimbursement after the fact. Gifts to family members of an employee are considered gifts to the employee when given with the employee's knowledge and acquiescence.

A gift does not include:

• Standard materials, activities, or programs related to a loan being provided
• Food, refreshments, or training furnished as part of a training session designed to improve lender service and contribute to professional development
• Favorable borrower benefits provided to a student employed by FCC if comparable terms are available to all FCC students
• Entrance and exit counseling services where FCC staff controls the session and no specific lender is promoted
• Philanthropic contributions to FCC unrelated to education loans
• State education grants, scholarships, or financial aid funds

FCC participates in the William D. Ford Federal Direct Loan Program through the U.S. Department of Education. FCC does not maintain a preferred lender list and will certify private loans from any lender. Terms, fees, and borrowing limits of private loans vary, and borrowing a private loan is a decision that should be made with careful consideration.

FCC prohibits any Financial Aid Office employee or agent from accepting any fee, payment, or financial benefit from a lender or affiliate as compensation for consulting arrangements or other contract services provided to or on behalf of a lender.

FCC prohibits assigning first-time borrowers to a particular lending institution through award packaging or other methods. FCC will not assign a borrower's private student loan to a particular lender. All decisions shall be made by the borrower through independent review. FCC will not refuse to certify or delay certification of any loan based on the borrower's selection of a particular lender or guaranty agency.

FCC prohibits any employee, officer, or agent from requesting or accepting from any lender an offer of funds for private education loans in exchange for concessions or promises regarding a specified number or volume of loans or a preferred lender arrangement.

FCC prohibits accepting or soliciting staffing assistance from a lending institution, including call center or financial aid office staffing. This does not prohibit requesting professional development training for aid officers, or requesting counseling, financial aid literacy, or debt management materials for borrowers, provided the materials disclose that the lender prepared or provided them.

Financial Aid Office employees who serve on an advisory board, commission, or group established by a lender or guarantor must not receive anything of value from that lender or guarantor, except reasonable expense reimbursement for serving on such board, commission, or group.