Student Loan Code of Conduct
Prohibition against remuneration to Kaskaskia College
- Kaskaskia College will not solicit, accept or agree to accept anything of value from any Lending Institution, Guarantee Agency or Servicer in exchange for any advantage or consideration provided by the Lending Intuition related to its student loan activity. This prohibition covers, but is not limited to:
- Revenue Sharing Agreements
- Any computer hardware which Kaskaskia college pays below market prices
- Any computer software used to manage loans unless the software can manage disbursements from all lenders
- Any printing costs, postage or services
- This does not prevent Kaskaskia College from soliciting, accepting
or agreeing to favorable terms and conditions where the benefit is made directly
to student borrowers.
Prohibition against remuneration to Kaskaskia College Employees
- Kaskaskia College will require and enforce that no officer, trustee, director, employee or agent of the college will accept anything more than a nominal value on his or her behalf or on behalf of another during the 12 month period from, or on behalf of a Lending Institution, Guarantee Agency or Servicer.
- This prohibition will include, but not be limited to a ban on any payment or reimbursement from any Lending Institution, Guarantee Agency or Servicer to College employees for lodging, meal, or travel to conferences or training seminars.
- This does not preclude any officer, trustee, director, employee or agent of the college from receiving compensation for conducting non-college business with a Lending Institution, Guarantee Agency, or Servicer or from accepting compensation that is offered to the general public.
- This prohibition does not prevent the college from holding membership in any non-profit professional associations.
Ban on Gifts
- No Kaskaskia College employee involved in the affairs of the college’s financial aid office shall solicit or accept any gift from a lender, guarantor, or servicer of educational loans.
- “Gifts” are defined as but not limited to:
- Any type of gratuity, favor, discount, entertainment, hospitality, loan, or other item having more than a token monetary value. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.
The following items would not be considered to be “Gifts”:
- Standard material, activities or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.\
- Food, refreshments, training, or informational material furnished to any officer, trustee, director or college employee, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such training contributes to the professional development of the officer, trustee, director or employee.
- Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the institution if such terms, conditions, or benefits are comparable to those provided to all students of the institution.
- Entrance and exit counseling services provided to borrowers to meet the institution’s responsibilities for entrance and exit counseling as required….”as long as”:
- The institution’s staff are in control of the counseling (and)
- Such counseling does not promote the products or services of any specific lender.
- Philanthropic contributions that are unrelated to education loans or any contribution not made in exchange for any advantage related to education loans.
- State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
Ban on gifts to family members
- Gifts to family members of any officer, trustee, director, or college employee
will be considered a gift to any said officer, trustee, director, or college
- The gift is given with the knowledge and acquiescence of the officer, trustee, director or university employee or
- The officer, trustee, director, or college employee has reason to
believe that the gift was given because of the official position of said
officer, trustee, director, or university employee
Limits of college employees participating on lender advisory boards
- Kaskaskia College will require and enforce that no officer, trustee, director or
employee of college will receive any remuneration for serving as a member or
participant of an advisory board of any Lending Institution, Guarantee Agency or
Servicer or receiving any reimbursement of expenses from said participation.
- This does not preclude any officer, trustee, director or employee from
participating on any lender advisory board that are unrelated to student loans.
- This does not preclude any Kaskaskia College employee not involved in the
affairs of the college’s financial aid office from serving on the Board of
Directors of a publicly traded or privately held company.
Contracting arrangements prohibited
- Any officer, trustee, director or employee is prohibited from accepting any
payments of any kind from a lender in exchange for any type of consulting
services related to educational loans.
- This does not prevent anyone else in the institution who has nothing to do
with student loans from entering into these agreements.
- This does not prevent anyone not employed in the financial aid office who has
“some” responsibility for student loans from entering into these agreements if
that individual in writing, recuses him or herself from any decision regarding
- This does not prevent anybody from serving on a Board of Director or trustee
of an institution if the individual recuses him or herself from any decision
regarding educational loans.
Revenue sharing agreements prohibited
- Kaskaskia College will not enter any revenue sharing agreement where:
- a lender provides or issues a loan that is made, insured, or guaranteed under
this title to students attending the institution or to the families of such
- the institution recommends the lender and in exchange the lender pays a fee or
provides other material benefits
Prohibition on offers of funds for private loans
- Kaskaskia College will not request or accept any agreement or offer of funds for
private loans in exchange for concessions or promises of:
- A specified number of loans made, ensured or guaranteed
- A specified loan volume
- A preferred lender arrangement
Ban on staffing assistance
- Kaskaskia College will not request or accept from any lender any assistance with
call center staffing or financial aid office staffing.
- This does not include: o Professional development training for financial
- Educational counseling materials, financial literacy materials, or debt
management materials to borrowers, provided that such materials disclose to
borrowers the identification of any lender that assisted in preparing or
providing such materials.
- Staffing services on a short-term, nonrecurring basis to assist the
institution with financial aid-related functions during emergencies, including
State-declared or federally declared natural disasters.
Interaction with borrowers
- Kaskaskia College participates in the Federal Direct Loan program and all
student and parent borrowers are packaged under that program. In respect to
- Kaskaskia College will not, for any first-time borrower, assign, through
award packaging or other methods, the borrower’s loan to a particular lender.
- Kaskaskia College will not refuse to certify, or delay certification of, any
loan based on the borrower’s selection of a particular lender or guaranty