Christian Theological Seminary Title IV Loan Program Code of Conduct
The following code of conduct applies to the officers, employees, and agents of Christian Theological Seminary (CTS). All CTS officers, employees, and agents with responsibilities with respect to Title IV Loans will be annually informed of the provisions of this Code of Conduct.
1) Officers, employees, and agents of Christian Theological Seminary shall not enter into a revenue-sharing arrangement, as defined by the Higher Education Opportunity Act (HEOA,) with any lender. The HEOA defines “revenue-sharing agreement” as any arrangement between an institution and a lender under which the lender makes Title IV loans to students attending the institution (or to the families of those students), the institution 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 institution or to its officers, employees, or agents.
2) Employees of the CTS Financial Aid Office may not accept gifts from a lender, guaranty agency or loan servicer. An officer or employee of the CTS Financial Aid Office (or any CTS employee or agent who otherwise has responsibilities with respect to educational loans) may not solicit or accept any gift from a lender, guarantor, or servicer of education loans. A “gift” is defined as any gratuity, favor, discount, entertainment, hospitality, loan, or other item having monetary value of more than a minimal amount ($10.00). A gift does not include:
(a) a brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy, such as a brochure, workshop or training;
(b) food, training, or informational material provided as part of a training session designed to improve the service of a lender, guarantor, or servicer if the training contributes to the professional development of the CTS officer, employee or agent;
(c) favorable terms and benefits on an education loan provided to a student employed by CTS if those terms and benefits are comparable to those provided to all CTS students;
(d) entrance and exit counseling as long as the CTS staff are in control of the counseling and the counseling does not promote the services of a specific lender;
(e) philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans or any contribution that is not made in exchange for advantage related to education loans, and;
(f) State education grants, scholarships, or financial aid funds administered by or on behalf or a State.
3) An officer or employee of the CTS Financial Aid Office (or CTS employee or agent who otherwise has responsibilities with respect to education loans) may not accept from a lender, or an affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
4) The CTS Financial Aid Office will not steer borrowers to particular lenders or assign, through the award packaging or other methods, a first-time borrower’s loan to a particular lender.
5) The CTS Financial Aid Office will not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty agency.
6) CTS will not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for 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 (or the student’s family) that involves a payment by an educational institution to the lender for extending credit to the student.
7) The CTS Financial Aid Office will not request or accept from any lender any assistance with call center staffing or financial aid office staffing, except professional development training, educational counseling materials which identify the lender that assisted in preparing the materials, or staffing services on a short-term, nonrecurring basis during emergencies or disasters.
8) An employee of the CTS Financial Aid Office (or CTS employee who otherwise has responsibilities with respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor, or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board.