Title IV Loan (Employees) School Code of Conduct

Bank Street College of Education, as a participant in federal loan programs, is required to develop, administer, and enforce a financial aid code of conduct applicable to the College’s officers, employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. Bank Street College of Education’s Code of Conduct Related to Student Loan Activities fulfills these requirements and applies to certain transactions and activities related to student lending and financial aid matters. Furthermore, Bank Street College of Education also adheres to the Student Lending, Accountability, Transparency and Enforcement (SLATE) Act under New York State law, which applies not only to the College’s officers, employees and trustees, but also to the College’s agents and contractors.

In addition, the financial aid professional at Bank Street College of Education is expected to always maintain exemplary standards of professional conduct in all aspects of carrying out his or her responsibilities, specifically including all dealings with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized, or regulated activity.

Revenue Sharing Prohibition – Bank Street College of Education employees are prohibited from receiving anything of value from any lending institution in exchange for any advantage sought by the lending institution.

Gift and Trip Prohibition – Bank Street College of Education employees are prohibited from taking anything of more than nominal value from any lending institution. This includes a prohibition on trips for financial aid officers and other college officials paid for by lenders.

Advisory Board Compensation Rules – Bank Street College of Education employees are prohibited from receiving anything of value for serving on the advisory board of any lending institution.

Staffing Assistance/Call-Center Prohibition – Bank Street College of Education employees are prohibited from accepting from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training, educational counseling materials  (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, nonrecurring basis during emergencies or disasters.

Consulting/Contracting Arrangement Prohibition – Bank Street College of Education employees are prohibited from accepting from any lender or affiliate of any lender any fee, payment, or other financial benefit 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.

Assigning of Lender to First-Time Borrower Prohibition – Bank Street College of Education Office of Financial Aid will not, for any first-time borrower’s, assign, through award packaging or other methods, the borrower’s loan to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.

Preferred Lender Lists – If Bank Street College of Education were to use a preferred lender list, the following standards shall be observed and maintained:

  1. A preferred lender list, if offered, will be based solely on the best interests of the students who may use the list without regard to financial interests of Bank Street College of Education.
  2. A preferred lender list, if offered, will have at least three (3) or more unaffiliated lenders.
  3. A preferred lender list, if offered, will clearly and fully disclose the criteria and process used by Bank Street College of Education to select the lenders on the list. Students will be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.
  4. Lenders listed on a preferred lender list, if offered, must first disclose if the lender has any agreement to sell its loans to another lender. No lender will be listed if they bargain to be on the list with respect to a certain type of loan by providing benefits to Bank Street College of Education as to another type of loan.
  5. A preferred lender list, if offered, will provide comparative information on borrower benefits offered by all lenders, including, but not limited to, lenders’ interest rates and loan terms and conditions.
  6. Bank Street College of Education will endeavor to select lenders with the best borrower benefits, including, but not limited to, lenders’ interest rates and loan terms and conditions, for its preferred lender list, if offered.
  7. Bank Street College of Education will annually update its preferred lender list, if offered.
  8. Bank Street College of Education will not be involved with any lender who undertakes philanthropic activities in exchange for federal student loan applications, volume, or placement on a school’s preferred lender list.