Mar 25, 2023  
Policies and Procedures Manual 
Policies and Procedures Manual

00:06:00 Title IV Loan Code of Conduct

Revision Responsibility: Vice President for Student Affairs
Responsible Executive Officer: Vice President for Student Affairs


To establish a code of conduct related to financial aid loans in compliance with Title IV.


All Administrators, employees and agents of Walters State Community College (WSCC) that have responsibilities with respect to student educational loans must fully comply with the following code of conduct:

  1. Revenue sharing arrangements are prohibited with any lender. This includes any instance in which an administrator, employee or agent of WSCC recommends a lender or loan products and in exchange the lender pays a fee or provides other material benefits, including revenue or profit sharing to the institution.
  2. Receiving of gifts from a lender, guarantor agency or loan servicer is prohibited. The term “gift” means: any gratuity, favor, discount, entertainment, hospitality, loan or other item valued at more than a de minimus amount. Gifts may include: services, transportation, lodging or meals whether provided in kind, by purchase of a ticket, payment in advance or by reimbursement. Gifts do NOT include:
    1. Standard material, activities, or programs on issues related to a loan;
    2. Food, refreshments, or training that are part of a training session to improve service if training contributes to professional development of agent;
    3. Favorable terms, conditions, and borrower benefits on a private education loan provided to a student employed in the institution if terms are comparable to those provided to all student employees;
    4. Entrance/exit counseling if school staff are in control and counseling does not promote products of any lender;
    5. Philanthropic contributions from a lender, servicer, or GA not related to or made in exchange for any advantage related to private education loans; state education grants, scholarships or financial aid funds administered on behalf of a state.
  3. Contractual Arrangements between administrators, employees or agents of the institution and lenders are prohibited. This includes consulting arrangements or other contracts for compensation to provide services to a lender or on the behalf of the lender relating to educational loans.
  4. Directing borrowers to particular lender is prohibited. This includes assigning first-time borrowers to a particular lender through an award or packaging process.
  5. Delaying or prohibiting certification based on a particular lender is prohibited.
  6. Offers of funds in exchange for a promise of a specified number of private education loans, a specified loan volume or a preferred lender arrangement for such loans is prohibited. This would include the “opportunity pool loan” which 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.
  7. Assistance with a call center or financial aid office staffing from a lender is prohibited. The institution may request or accept the following: professional development training for aid officers; Counseling, financial literacy or debt management materials for borrowers if materials disclose that lender prepared or provided the materials; Staffing on a short-term nonrecurring basis to assist with aid related emergencies.
  8. Those who serve on an advisory board, commission or group established by a lender that have responsibilities with respect to private education loans are prohibited from receiving anything of value from such entities. However, an exception may be applied to allow reimbursement for reasonable expenses incurred in serving on such advisory board, commission or group.