The following provisions constitute Ithaca College’s Student Loan Code of Conduct, as required by the Higher Education Opportunity Act of 2008 (HEOA). The College also complies with the New York State Student Lending Accountability, Transparency, and Enforcement Act. Such code must prohibit a conflict of interest with the responsibilities of an officer, employee, or agent of an institution with respect to such loans, and include the provisions outlined in the HEOA related to conflicts. The following conduct is prohibited:
- Ithaca College employees shall not receive any personal benefit. No officer or employee of the College shall accept or solicit anything of more than nominal value on his or her behalf or on behalf of another person or entity from any Lending Institution. For example, cash, stocks, gifts, entertainment, expense-paid trips, computer hardware for which the recipient pays below market value prices, etc. should never be accepted from a Lending Institution. Likewise, an individual should never receive payment or reimbursement from a Lending Institution for lodging, meals, or travel to conferences or training seminars. An individual may attend conferences and meetings of tax-exempt organizations that are funded or sponsored by more than one entity and, subject to state law, receive materials, refreshments, and other things of like value provided at such professional conferences and meetings
A gift does not include (1) standard materials, activities, or programs on issues relating to a loan, default aversion, or financial literacy, such as a brochure, workshop or training; (2) food, refreshments, training, or informational material provided as part of a training session designed to improve the service of a lender, guarantor, or servicer of education loans if the training contributes to the professional development of College officers, employees or agents; (3) favorable terms and benefits on an education loan provided to a student employed by the College, if those terms and benefits are comparable to those provided to all students at the College; (4) entrance and exit counseling, provided that College staff are in control of the counseling and the counseling does not promote the products or services of any specific lender; (5) philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans and; (6) State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
- Ithaca College shall not enter into any revenue-sharing arrangements with a lender. A revenue-sharing arrangement is any arrangement under which a lender makes private education loans to students attending the College (or to their families), the College recommends the lender or the loan products of the lender and, in exchange, the lender pays a fee or provides other material benefits, including revenue or profit‐sharing, to the College or to its officers or employees.
- Ithaca College employees shall not serve on lender advisory boards or other contracts to provide services to lenders for compensation. No officer or employee of the College who makes financial aid decisions for the College or who is employed in, supervises or otherwise has responsibility or authority over the College’s financial aid office shall receive any remuneration for serving as a member or participant of a student loan advisory board of a Lending Institution or any reimbursement of expenses for such service. Any officer, trustee, or employee of the College who serves as a member or participant of a Lending Institution board shall recuse himself or herself from any board discussions regarding the College’s financial aid operations.
- Ithaca College shall make appropriate use of any Preferred Lender Lists. If the College decides to promulgate a list or lists of preferred or recommended lenders for student loans or similar ranking or designation (“Preferred Lender List”), the selection of Lending Institutions for inclusion on the Preferred Lender List shall be based on the best interests of the College’s students and their parents without regard to the financial interests of the College.
Violations of College policies, including the failure to avoid a prohibited activity or disclose a conflict of interest in a timely manner, will be dealt with in accordance with applicable college policies and procedures, which may include disciplinary actions up to and including termination from the institution.
Updated February 25, 2021