Code of Conduct

Title IV Loan Code of Conduct

In order to comply with regulations set forth in the Higher Education Opportunity Act (HEOA), Thomas College has implemented this Title IV Loan Code of Conduct. The HEOA stipulates that an institution of higher education participating in the Title IV loan program create, manage and implement a code of conduct prohibiting conflicts of interest for its financial aid personnel. All officers, employees and agents of the College who have educational loan responsibilities are affected by the code. The aforementioned individuals must be notified of the provisions contained within the code of conduct annually. Thomas College’s Title IV Loan Code of Conduct reads as follows:

  1. Thomas College nor any individual officer, employee or agent of Thomas College shall enter into any revenue-sharing arrangements with any lender.
  2. Thomas College does not permit any officer, employee or agent of the College who is employed in student financial services or who otherwise has responsibilities with respect to educational loans, or any of their family members, to solicit or accept any gifts of greater than a nominal value from a lender, guarantor, or servicer of educational loans.
  3. Thomas College does not permit any officer, employee or agent of the College who is employed in student financial services or who otherwise has responsibilities with respect to educational loans, to accept from any lender or affiliate of any lender any fee, payment, or other financial benefit (including a stock purchase option) as compensation for any type of consulting arrangement or other contractual arrangement to provide services to a lender or on behalf of a lender relating to educational loans.
  4. Thomas College does not permit any officer, employee or agent of the College who is employed in student financial services or who otherwise has responsibilities with respect to educational loans, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors to accept any thing of value from a lender, guarantor, or group of lenders or guarantors in exchange for such service. Exception is given for reimbursement for reasonable expenses incurred in serving on such advisory board, commission, or group.
  5. Thomas College is a Direct Loan only institution with respect to Stafford and PLUS loans. With respect to all other educational loans Thomas College does not assign, through award packaging or other methods, the borrower’s loan to a particular lender; nor does Thomas College refuse to certify, or delay certification of, any loan based on the borrower’s selection for a particular lender or guaranty agency.
  6. Thomas College will not request or accept from any lender any offer of funds to be used for private educational loans to students in exchange for the institution providing concessions or promises regarding providing the lender with a specified number or volume of loans made, insured, or guaranteed under Title IV, or a preferred lender arrangement for Title IV loans.
  7. Thomas College shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing.