Code of Conduct Proposed Addition: Financial Aid Code of Conduct: Del Mar College and its employees and agents shall comply fully with state and federal laws relating to student loans. A Financial Aid Code of Conduct ensures the integrity of the student loan process and is critical to providing fair and affordable access to higher education at Del Mar College. All College decisions concerning student loans are made with integrity, free from conflicts of interest, and in the best interest of the borrowers. Code of Conduct Statement: DMC is a full participant of the William D. Ford Federal Direct Loan (Direct Loan) Program. The College is committed to allowing students complete freedom of choice in financing their education. Students may choose to borrow money under the Federal Direct Loan programs, take loans from private lenders, or use federal programs in addition to private sources. The Code of Conduct pertains to loans taken from Federal Direct Loan programs, the Parent Loan for Undergraduate Students (PLUS) program, and from private lenders. Definitions Employee: Any employee, agent, student financial aid contractor, director, officer, or Regent of the College. For purposes of the Code of Conduct provisions relating to gifts and stock ownership, this term includes family members of the employee living in the same household as the employee. Gift: Any discount, favor, gratuity, inducement, loan, stock, thing of value, or other item having more than nominal value, including payment of meals and entertainment expenses but not including (i) a Lender’s own brochure or informational material, (ii) food or informational materials provided as an integral part of training designed to improve the lender’s service to the College and which leads to the professional development of College staff, or (iii) food or receptions at conferences that are open to all conference attendees. Lender: (a) Any entity that, itself or through an affiliate, makes educational loans to finance higher education expenses or that securitizes such loans; (b) any entity or association that guarantees educational loans; or (c) any industry, trade or professional association or other entity that receives money, related to educational loan activities, from any entity described in (a) or (b) above. High Risk Loan: A loan that, because of a borrower’s credit history (or lack thereof), would not ordinarily be available to a borrower in the absence of a College agreement to provide concessions or anything of value to the Lender. Compensation from Lenders: DMC will not, directly or indirectly, solicit, accept or receive any Gift or payment from or on behalf of a Lender, in exchange for (i) referring borrowers to the Lender, (ii) loan volume from DMC borrowers, (iii) placement on a preferred lender list, or (iv) giving that Lender any advantage or consideration related to the lender’s marketing or lending to DMC borrowers. The College will not engage in revenue sharing with a Lender. Revenue sharing is any arrangement by which a Lender pays DMC a percentage of the principal of a loan taken out by a borrower at DMC. No College employee with responsibilities relating to financial aid may, on his or her own behalf or on behalf of another, directly or indirectly, solicit, accept or receive any gift from or on behalf of a Lender. No employee whose responsibilities do not relate to financial aid may on his or her own behalf or on behalf of another, directly or indirectly, solicit, accept or receive any gift from or on behalf of a Lender in return for providing the Lender any advantage or consideration related to the Lender’s marketing or lending to DMC borrowers. Any person who learns of a Lender giving or attempting to give a gift in violation of the above shall report that information to the College President or the Vice President of Student Services. Nothing in this Code of Conduct shall be construed to affect or prevent the philanthropic activities of financial institutions that are unrelated to educational loans. Participation on Lender Boards: An employee of the College Financial Aid Office, or an employee who otherwise has responsibilities with respect to education loans or financial aid, who serves on an advisory board 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 advisory board. Staffing of College Offices: No employee or agent of a Lender may staff any DMC financial aid-related office, or be identified to any borrower or potential borrower as an employee, representative or agent of the College. Information Disclosure to Borrowers: Any borrower or potential borrower who consults a DMC financial aid office will be informed of all available financing options available under Title IV of the Federal Higher Education Act of 1965, as amended, including information on any terms and conditions of available loans under that Title that are more favorable to the borrower, before the College may process or accept funds from a private loan. No Lender may provide in-person initial or exit counseling to DMC borrowers. High Risk Loans: The College will not enter into any agreement or otherwise provide any high risk loan in exchange for a promise to give concessions or other advantages to Lenders that may prejudice other borrowers or potential borrowers. Preferred Lender Lists: The College will not publish or give students a preferred lender list. The College will not deny or otherwise impede a borrower’s choice of lender. DMC will not direct any PLUS or private loan borrower to any electronic master promissory note or other agreement that does not provide a reasonable and convenient alternative for the borrower to complete a master promissory note with any approved lending institution. Reporting Violations: Any person who has reason to believe Del Mar College or an employee has violated this Code of Conduct should report that information promptly to the College President, 361-698-1203 or to the Office of the Vice President of Student Services, 361-698-1277. Penalties: Penalties for violating this Code of Conduct may include disciplinary action, up to and including separation from the College, as well as civil and criminal liability.