U.S. Department of Education Title IV Code of Conduct Requirements And Preferred Lender Selection

adopted by Heidelberg University 6-9-09
updated 11-30-2010

  1. A ban on revenue-sharing arrangements with any lender. This is defined as any arrangement between Heidelberg University and a lender that results in the lender paying a fee or other benefits, including a share of the profits, to Heidelberg, its officer, employees or agents, as a result of us recommending the lender to our students or families.
  2. A ban on employees of the financial aid office receiving gifts from any lender, guaranty agency or loan servicer offering any educational loans, including Title IV and private loans. The law does provide for some exceptions related to specific types of activities or literature. This includes:
    1. Brochures or training material related to default aversion or financial literacy.
    2. Food, training or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training.
    3. Favorable terms and benefits to the student employed by the institution as long as those same terms are provided to all students at the institution.
    4. Entrance and exit counseling as long as the institution’s staff are in control and they do not promote the services of a specific lender.
    5. Philanthropic contributions from a lender, GA or servicer unrelated to education loans.
    6. State education, grants, scholarships, or financial aid funds administered by or on behalf of the State.
  3. A ban on contracting arrangements whereby any employee of Heidelberg’s financial aid office may not accept any fee, payment or 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. A prohibition against Heidelberg employees steering borrowers to particular lenders, or delaying loan certifications. This includes assigning any first-time borrower’s loan to a particular lender as part of our award packaging or other methods.
  5. A prohibition on offers of funds for private loans. Heidelberg University will not request or accept such offers. This includes any offer of funds for loans to students at the institution, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans, or inclusion on a preferred lender list.
  6. A ban on staffing assistance from a lender. Heidelberg University will not request or accept any assistance with call center staffing or financial aid office staffing. However, Heidelberg can request or accept assistance from a lender related to:
    1. Professional development training for financial aid administrators.
    2. Providing 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.
    3. Staffing services on a short-term, nonrecurring basis to assist the school with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, and other localized disasters and emergencies identified by the Secretary.
  7. A ban on advisory board compensation. Employees of Heidelberg University may not receive anything of value from a lender, guarantor, or group in exchange for serving in this capacity. We may, however, accept reimbursement for reasonable expenses incurred while serving in this capacity.
  8. Private loan lenders are selected annually based upon the following criteria:
    1. excellent terms and benefits they provide borrowers
    2. exceptional customer service
    3. competitive rates with regard to interest and loan origination fees
    4. timely processing
    5. electronic funds transfer capabilities
  9. Students are free to select any lender they wish, even one not on Heidelberg’s listing.