Colleges participating in any of the Title IV loan programs are required by the Department of Education to develop, publish and enforce a code of conduct. The below code of conduct applies to all officers, employees and agents of Vernon College.
Ban on revenue sharing arrangement with any lender
Neither Vernon College as an institution nor any individual officer, employee or agent is permitted to enter into a revenue sharing agreement with any lender. This is defined as any arrangement between a school and a lender that results in the lender paying a fee or other benefits, including a share of the profits, to the school, its officer, employees or agents, as a result of the school recommending the lender to its student or families of those students.
Ban on receiving gifts from a lender, guaranty agency or loan servicer
Vernon College does not allow any officer or school employee who is employed in the financial aid office who has responsibilities related to education loans to solicit or accept any gift from a lender, guarantor, or servicer of education loans. For purposes of this prohibition, the term “gift” means any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than $10.
Ban on contracting arrangements
Vernon College does not permit an officer or employee of the financial aid office or an agent who has responsibilities related to education loans to accept any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation from any lender or affiliate for any type of consulting arrangement or other contract to provide services to the lender or on behalf of the lender with regard to education loans.
Prohibition against steering borrowers to particular lenders or delaying loan certifications
Vernon College does not assign any first-time borrower’s loan to a particular lender through award packaging or any other means. In addition, the financial aid personnel will not refuse to certify or delay certification of any loan based on the borrower’s selections of a particular lender or guaranty agency.
Prohibition of offers of funds for private loans
Vernon College does not request or accept funds from any lender for private education loans, including funds for an opportunity pool loan, for students in exchange for providing concessions or promises to the lender regarding a specific number of Title IV loans made, insured or guaranteed, a specified loan volume, or a preferred lender arrangement. An “opportunity pool loan” is defined as a private education loan made by a lender to a student that involves a payment by the institution to the lender for extending credit to the student.
Ban on staff assistance
Vernon College does not request or accept any assistance with call center staffing or financial aid office staffing from any lender.
Ban on advisory board compensation
Any employee who is employed in the financial aid office, or who otherwise has responsibilities with respect to education loans or other student financial aid, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, shall be prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.