Student Loan Code Of Conduct
Educational loans are an important resource for many students and parents who borrow
to help finance higher education. Eastern Kentucky University students and families
must receive trustworthy, reliable guidance from institutions about financial aid,
including educational loans. The following guidelines are a framework to provide the
best possible loan terms for the students served by EKU and to avoid conflicts or
the appearance of conflicts of interest.
1. EKU shall not enter into any revenue-sharing arrangements with any lender.
A revenue-sharing arrangement is defined as any arrangement between an institution
and a lender under which the lender provides or issues private education 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. No officer or employee of the financial aid office (or an employee or agent
who otherwise has responsibilities with respect to educational loans) may 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 de minimus amount. The term gift also includes
services, transportation, lodging, or meals, whether provided in kind, by purchase
of a ticket, payment in advance, or by reimbursement. The term gift does not include
the following: (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 the agent;
(3) favorable terms, conditions, and borrower benefits on a private education loan
provided to a student employed in the financial aid office 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 the products of any lender; (5)
philanthropic contributions from a lender, servicer or guarantee agency not related
to or made in exchange for any advantage related to private education loans; or (6)
state education grants, scholarships, or financial aid funds administered on behalf
of a State.
3. An employee of the financial aid office (or an employee who otherwise has responsibilities
with respect to private education loans or financial aid) who serves on an advisory
board, commission, or group established by a lender or group of lenders is prohibited
from receiving anything of value from such entities, except the employee may be reimbursed
for reasonable expenses incurred by the employee for serving on such boards, commissions
4. No officer or employee of the financial aid office (or an employee or agent
who otherwise has responsibilities with respect to educational loans) may 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 educational loans.
5. Officers or employees of the financial aid office shall not steer borrowers
to particular lenders or delay loan certifications. For any first-time borrower,
EKU will not assign, through award packaging or other methods, the borrower’s loan
to a particular lender. In addition, the university shall not refuse to certify,
or delay the certification, of any loan based on the borrower’s selection of a particular
6. Eastern Kentucky University shall 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 promise of a specific number of private education
loans, a specific loan volume, or a preferred lender arrangement for such loans.
An opportunity pool loan means a private education loan that involves a payment, directly
or indirectly, by the institution of points, premiums, additional interest or financial
support to the lender for the purpose of the lender extending credit to the student.
7. Eastern Kentucky University shall not request or accept from any lender any
assistance with call center or financial aid office staffing, except the institution
is not prohibited from requesting/accepting the following: (1) professional development
training for aid officers; (2) counseling, financial literacy, or debt management
materials for borrowers as long as materials disclose that the lender prepared or
provided the materials; or (3) staffing on a short-term, nonrecurring basis to assist
with aid-related functions during an emergency.
8. The university’s lender comparison chart shall include all lenders used by
enrolled borrowers during the most recent three year period. The lender list shall
be readily available via the campus website. All materials and information shall inform
students that they have the right to use any lender listed on the comparison chart
or any other lender of their own choosing.