The Higher Education Act requires Westminster College (referred to throughout this document as “the
institution”) to develop, administer, and enforce a Code of Conduct with respect to private education
loans. This Code of Conduct addresses standards of business for the working relationships between
college officials and private loan lenders.
A private education loan is any loan that is not under Title IV of the HEA and is issued to a borrower
expressly for postsecondary education expenses, regardless of whether the loan is provided through the institution that the student attends or directly to the borrower from the lender.
I. Revenue-sharing Arrangements with Any Lender
The institution will not enter into any revenue-sharing arrangement with any lender.
Specifically, the institution will not recommend a lender or loan products of a lender in
exchange for a fee or other material benefit, including revenue or profit sharing.
No agent for the institution who is employed in the Financial Aid Office or who has
responsibilities with private education loans may solicit or accept any prohibited gift from a
lending institution. Prohibited gifts include: any gratuity, favor, discount, entertainment
(including expenses for shows, sporting events, or alcoholic beverages), hospitality (including
private parties of select training or conference attendees), loan, or other item having a
monetary value of more than a de minimus amount. A gift includes 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.
An agent of the institution may accept items of a de minimus amount from a private education
lender that are offered as general marketing or advertising or to create good will. Examples of
de minimus gifts include, but are not limited to: pens or pencils, notepads, sticky-notes, rulers,
calculators, small tote bags, calendars, and other office supply items.
III. Philanthropic Gifts and Contributions to the Institution
The College will not accept any philanthropic contributions from a lending institution that are
related to the loans that are provided to our students, or that is provided to gain an advantage
related to private education loans. In addition, we will not accept scholarships or grants from a
private lending institution in exchange for loan applications or referrals for applications, or for a
specific volume or dollar amount of private loans received.
The College may accept philanthropic contributions from a lender that are not related to the
loans provided to our students, or that is not provided in exchange to receive an advantage
related to private education loans.
IV. Consulting or Other Contractual Arrangements
An agent of the institution who is employed in the Student Service Center and/or has direct
responsibilities with the private education loan programs may not accept from any lending
institution any compensation for any type of consulting arrangement or other contract to
provide services to or on behalf of the lender. An agent of the institution can be permitted to
engage in these consulting activities as long as they are not employed in the Financial Aid Office
or as long as they do not have direct responsibilities related to private education loans.
V. Choice of Lender
Agents of the institution will not:
- Assign the student’s loan to a particular lender
- Encourage or influence the student to choose a specific lender
- Show preference for one lender over another
- Refuse to certify, or cause delays in loan processing for a borrower based on their choice
VI. Opportunity Pools
For purposes of this document, an opportunity pool is defined as a private education loan made
by a lender to a student attending this institution or the student’s family member that involves
the College paying points, premiums, additional interest, or financial support to the lender for
the purpose of that lender extending credit to the borrower.
The institution will not request or accept an offer of funds from an opportunity to be used for
private education loans.
VII. Staffing Assistance
The institution will not request or accept from any lender any assistance with call center staffing
or financial aid office staffing.
VIII. Advisory Board Compensation
An agent for the institution with direct private education loan responsibilities may not accept
anything of value in exchange for service on an advisory board established by a lending
institution. If an agent of the institution without private education loan responsibilities does
serve on an advisory board established by a lending institution, the agent may accept
compensation for reasonable expenses incurred by that service