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Student Financial Aid Services Staff Code of Conduct Policy

Preamble

This Code of Conduct describes the policies and rules of Tarrant County College (TCC) relating to student loans. The Code applies to all employees, officers and agents of TCC. It is intended to ensure that the College and its employees and agents comply fully with state and federal laws governing this area, and that all College decisions concerning student loans are made with integrity, free from conflicts of interest, and in the best interests of the borrowers. Ensuring the integrity of the student loan process is critical to providing fair and affordable access to higher education at TCC.

TCC is a full participant of the William D. Ford Federal Direct Loan (Direct Loan) Program. TCC students finance the cost of their education in various ways. The College is committed to allowing students complete freedom of choice in how they finance their education. Many will choose to borrow money under the Federal Direct Loan programs, but many take loans from private lenders, in some cases as part of federal programs and also in addition to them. This code pertains to loans taken from PLUS and private lenders.

Code of Conduct

Compensation from Lenders

  1. TCC will not, directly or indirectly, solicit, accept or receive any Gift or payment from or on behalf of a Lender, in exchange for
    1. referring borrowers to the Lender,
    2. loan volume from TCC borrowers,
    3. placement on a preferred lender list, or
    4. for giving that Lender any advantage or consideration related to the lender's marketing or lending to TCC borrowers.
  2. TCC will not engage in revenue sharing with a Lender. Revenue sharing is any arrangement by which a Lender pays TCC a percentage of the principal of a loan taken out by a borrower at TCC.
  3. No TCC employee with responsibilities relating to financial aid may, on his or her own behalf or on behalf of another, directly or indirectly, solicit, accept or receive any Gift from or on behalf of a Lender. No employee whose responsibilities do not relate to financial aid may on his or her own behalf or on behalf of another, directly or indirectly, solicit, accept or receive any Gift from or on behalf of a Lender in return for providing the Lender any advantage or consideration related to the Lender's marketing or lending to TCC borrowers. Any person who learns of a Lender giving or attempting to give a Gift in violation of the above shall report that information to the TCC In House Counsel.
  4. "Employee" or "school employee" means any employee, agent, student financial aid contractor, director, officer or trustee of the school. For purposes of the Code provisions relating to gifts and stock ownership, this term includes family members of the employee. For purposes of this Code, this term includes family members living in the same household as the employee.
  5. Nothing in this Code shall be construed to affect or prevent the philanthropic activities of financial institutions that are unrelated to educational loans.

Lender Boards

  1. Neither TCC nor any employee may receive from a Lender any remuneration or reimbursement of expenses for serving on, performing duties for, or attending meetings of, a Lender's advisory board or council. Any employee who serves on a Lender advisory board may have appropriate, related expenses reimbursed by TCC in accordance within then-applicable TCC policy.
  2. Nothing in this Code shall prohibit
    1. an employee from serving on an advisory board of a Lender that is unrelated in any manner whatsoever to educational loans or
    2. an employee whose duties do not relate to financial aid from serving on the board of directors of any publicly traded or privately held company.

Staffing of TCC Offices

  1. No employee or agent of a Lender may staff any TCC financial aid-related office or be identified to any borrower or potential borrower as an employee, representative or agent of TCC.

Information Disclosure to Borrowers

  1. Any borrower or potential borrower who consults a TCC Financial Aid Office will be informed of all available financing options available to him or her under Title IV of the Federal Higher Education Act of 1965, as amended, including information on any terms and conditions of available loans under that Title that are more favorable to the borrower, before TCC may process or accept funds from a private loan.
  2. No Lender may provide in-person initial or exit counseling to TCC borrowers.

High Risk Loans

  1. TCC will not enter into any agreement or otherwise provide any high risk loan in exchange for a promise to give concessions or other advantages to Lenders that may prejudice other borrowers or potential borrowers.

Preferred Lender Lists

  1. The College will not publish or give students a preferred lender list. The College will not deny or otherwise impede a borrower's choice of lender.
  2. TCC will not direct any PLUS or private loan borrower to any electronic master promissory note or other agreement that does not provide a reasonable and convenient alternative for the borrower to complete a master promissory note with any approved lending institution.

Reporting Violations

  1. Any person who has reason to believe TCC or an employee has violated this code of conduct should report that information promptly to the In House Counsel. Reports may also be made to the Vice Chancellor for Administration and Community Services at 817-515-5243.

Penalties

  1. Penalties for violating this code may include disciplinary action, up to and including separation from the College, as well as civil and criminal liability.

Definitions

  1. "Gift" means any discount, favor, gratuity, inducement, loan, stock, thing of value, or other item having more than nominal value. It includes payment of meals and entertainment expenses but does not include
    1. a Lender's own brochure or informational material,
    2. food or informational materials provided as an integral part of training designed to improve the lender's service to TCC and which leads to the professional development of TCC staff, or
    3. food or receptions at conferences that are open to all conference attendees.
  2. "Lender" means
    1. any entity that, itself or through an affiliate, makes educational loans to finance higher education expenses or that securitizes such loans;
    2. any entity or association that guarantees educational loans, or
    3. any industry, trade or professional association or other entity that receives money, related to educational loan activities, from any entity described in a) or b) above.
  3. "High Risk Loan" means a loan that, because of a borrower's credit history (or lack thereof), would not ordinarily be available to a borrower in the absence of TCC's agreement to provide concessions or anything of value to the Lender.

Updated April 06, 2017