Incentive Compensation

Bank Street College of Education under statutory language will not provide a commission, bonus or other incentive payment based in any part, directly or indirectly on success in securing enrollments or financial aid to any person or entity engaged in any student recruiting or admission activities or in making decisions regarding awarding Title IV funds.

In addition, Bank Street College of Education is prohibited from making adjustments to compensation for any employee engaged in any student recruiting or admission activities or in making decisions regarding awarding financial aid.

An annual adjustment in a calendar year is acceptable if the institution (Bank Street College of Education) can document that said adjustment is not based upon enrollments.

Multiple adjustments in a calendar year are considered to have been made based upon success in securing enrollments or awarding financial aid if those adjustments create compensation based in any part, directly or indirectly on securing enrollment or awarding financial aid.

Bank Street College of Education, its contractors and other entities may make acceptable compensation in the form of profit-sharing payments so long as such payments are not provided to any person who is engaged in student recruitment or admission activity or in making decisions regarding the award of Title IV funds.

Commission, bonus, or other incentive payment is defined as a sum of money or something of value, other than a fixed salary or wages, paid or given to a person or entity for services rendered.

Enrollment is defined as admission or matriculation of a student into an eligible institution.

Securing enrollment or the award of financial aid is defined as activities a person/entity engages in at any point in time through completion of an educational program for the purpose of admission or matriculation of students for any period of time or the award of financial aid to students.

Entity/person engaged in any student recruitment or admission activity or in making decisions about the award of financial aid means any institution or organization that undertakes the recruiting or the admitting of students or that makes decisions about and awards Title IV funds; and

Any person who undertakes recruiting or admitting of students or who makes decisions about and awards Title IV funds, and any higher level employee with responsibility for recruitment or admission of students, or making decisions about awarding Title IV funds.