Statement of Policy:

Manor College strives to avoid conflicts of interest and self-dealing in its Financial Aid office by following the Financial Aid Code of Conduct, which is intended to comply and be interpreted in conformity with the Higher Education Opportunity Act of 2008 (“HEOA”).

Scope of Policy:

This policy applies to all Manor College Officers, employees, and agents with responsibility for student educational loans.

Administrative Guidelines:

I. Loan Award and Certification:
No Agent of Manor College who is employed in the Financial Aid Office of the College or otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, shall accept from any lender or affiliate of any lender any fee, payment or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.

II. Ban on Receipt of Gifts
No Agent of Manor College shall solicit or accept any “gift” from a lender, guarantor, or servicer of education loans. “Gift” includes any gratuity, favor, discount, entertainment, hospitality, loan or other item having monetary value of more than a minimal amount. This includes a gift of services, transportation, lodging or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.

This prohibition also applies to gifts to family members of the above individuals when the gift was given with the knowledge and acquiescence of such individual and the individual has reason to believe the gift was given because of such individual’s official position.

III. Ban on Revenue-Sharing Arrangements
Manor College will not enter into any “revenue-sharing arrangement” with any lender. A “revenue sharing arrangement” is an arrangement whereby the College recommends a lender of educational loans, and then in exchange, the lender pays a fee or provides other material benefits, including revenue or profit-sharing, to the College, or an Agent of the College.

IV. Ban on Compensation for Service on Advisory Board
No employee who is employed in Manor College’s Financial Aid Office, or who otherwise has responsibilities with respect to education loans or other student financial aid of the College, and who serves on an advisory board, commission, or group of lenders or guarantors, shall be permitted to receive anything of value from the lender, guarantor, or group of lenders or guarantors, except for reimbursement for reasonable expenses incurred in serving on such advisory board, commission, or group.

V. Ban on Offers of Funds for Private Loans
Manor College shall not request or accept from any lender any offer of funds to be used for private education loans for students, including funds for an “opportunity pool loan,” in exchange for the institution providing concessions or promises to provide the lender with:

1.  a specified number of loans made, insured or guaranteed;
2.  a specified loan volume; or,
3.  a preferred lender arrangement.

An “opportunity pool loan” means a private education loan made by a lender to a student attending the College or a family member of the student, that involves a payment, directly or indirectly, by the College of points, premiums, additional interest, or financial support to the lender for the purpose of the lender extending credit to the student or the student’s family.

VI. Ban on Staffing Assistance
Manor College shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing. However, this prohibition does not preclude requesting or accepting assistance from a lender related to:

1.  professional development training for financial aid administrators;
2.  providing educational counseling, financial literacy or debt management materials to borrowers that identify the lender who assisted in preparing or providing the materials; or
3.  staffing services on a short term, nonrecurring basis to assist the College with financial aid-related functions during emergencies.

VII. Ban on Contracting Arrangements with Lenders
No officer or employee of Manor College who is employed in the financial aid office of the College or otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, shall accept from any lender or affiliate of any lender any fee, payment or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.