Title IV Loan School Code of Conduct Policy
(Based on Federal Regulations and the Higher Education Opportunity Act)
Personnel Affected
This code of conduct applies to all financial aid employees and all other employees and agents who have responsibilities with respect to educational loans or who have contact with guaranty agencies or lenders (either federal or private loan lenders). All decisions and actions must be consistent with the following principles:
Student Choice
All students must be given an equal and fair opportunity to choose from all lenders and loans, federal and private. These choices will not be limited to lenders or loans that are available through or recommended by The Salon Professional Academy.
Student Interests
The Salon Professional Academy will seek to ascertain relationships with those lenders which can provide the best benefits for students—interest rates and fees, payment terms and services.
Avoidance of Conflict of Interests
A conflict of interest is created when an employee’s personal situation interferes with her judgment which can make her unable to act in the best interest of The Salon Professional Academy or the students attending the institution. All employees must avoid conflicts of interest. No employee shall have any relationship with any lender or guaranty agency nor accept any fees or anything of value, other than token marketing items and nominal conference refreshments, from any lender.
The Salon Professional Academy will not accept any service or anything of value from any lender or guaranty agency with exception of the following services: loan processing materials and financial literacy materials, training for financial aid staff related to loan processing, entrance and exit counseling services conducted under the supervision of a financial aid administrator from The Salon Professional Academy, emergency staffing services, and/or reimbursement of reasonable costs for domestic travel and training conferences hosted by lenders and/or guaranty agencies.
Student Privacy
All student financial information must be kept confidential. This includes but is not limited to information based on need, resources, loans and other aid. This information cannot be shared with outside parties, without written student authorization, other than the United States Department of Education (DOE), state aid agencies, lenders, servicers and guaranty agencies.
Code of Conduct
All financial aid employees and all other employees and agents are required to comply with all of the following rules in this Code of Conduct Regarding Lender Relationships and Loans. In addition, they are required to notify the Director/Owner if they become aware of facts indicating that there may have been a violation of the Code of Conduct Regarding Lender Relationships and Loans.
Prohibited Relationships
No financial aid employee or any other employee or agent, shall act as an employee, consultant or sales representative or officer for any lender or guaranty agency. No financial aid employee or other employee shall serve on the Board of Directors (compensated or uncompensated) for any lender or guaranty agency.
No financial aid employee or any other employee shall serve on any lender or guaranty agency’s advisory board. No agent of The Salon Professional Academy will be allowed to serve on a lender or guaranty agency’s advisory board without written approval from the Director/Owner to ensure the agent will comply with this policy.
Prohibited Investments
No financial aid employee or any other employee or agent shall buy or accept any stock, bond or other equitable or legal interest in any lender or guaranty agency. In addition, any option to acquire such an interest will also be prohibited with the exception of ownership units in mutual fund holdings such as stocks or bonds.
Prohibited Benefits or Gifts
No financial aid employee or any other employee or agent shall accept any gift, prize, compensation, entertainment (including concerts and/or sporting event tickets), travel cost reimbursement, meals or any other benefit (herein referred to as “prohibited benefits”) from any lender or guaranty agency. This does not include promotional items of nominal value, meals and/or refreshments open to all attendees at a conference, and reasonable reimbursement for costs related to domestic travelling to attend seminars or conferences which provide training on the administering of loans. Agents will also be allowed reasonable domestic travel reimbursement for costs to attend advisory board meetings which are focused on best practices. Any and all circumstances of lenders or guaranty agencies attempting to offer any prohibited benefits shall be immediately reported to the Owner/Director, as well as any applicable state agencies.
Prohibited Benefits or Inducements to the Institution
The Salon Professional Academy will not accept from any lender revenue sharing arrangements, revenue sharing, any “opportunity pool”, or similar funding arrangements offered in exchange for making private loans to higher risk students in exchange for promises or concessions by The Salon Professional Academy.
Prohibited Promotions
The Salon Professional Academy will not allow any guaranty agency or lender to use our name, logo, or any other symbols, words or photographs readily associated with The Salon Professional Academy for advertisement, publication or any other communication purposes which would imply or suggest that The Salon Professional Academy endorses any services or loans guaranteed or offered by the lender or guaranty agency. In addition, The Salon Professional Academy will ensure that all materials about federal or private education loans that are provided to students will clearly identify the name of the lender.
Prohibited Representations and Services
The Salon Professional Academy will not allow any lender or guaranty agency’s employee, representative, or agent to represent himself/herself to the public or to otherwise act as a representative or agent of The Salon Professional Academy.
The Salon Professional Academy will not allow any employee, representative, or agent to represent himself/herself to the public or to otherwise act as a representative or agent of any lender or guaranty agency.
The Salon Professional Academy generally will not accept from any guaranty agency or lender any assistance for the financial aid office. Staffing assistance on a short term basis in the event of an emergency created by a disaster, entrance and exit counseling services which are supervised by a financial aid administrator, or financial literacy materials which do not promote any specific guaranty agency or lender may be accepted as deemed necessary by the Owner/Director.
Prohibited Inducements by The Salon Professional Academy
The Salon Professional Academy will not offer or provide any particular kind of loans or scholarships, inducement to secure any business relationship or any other benefits or services to any lender or guaranty agency. This includes but is not limited to the promise of a loan volume or any other benefit or advantage.
Loan Processing Arrangements
The Salon Professional Academy will not use any software or processing system or practice which will create a ‘default’ arrangement which will cause the student borrower to automatically be referred to any one or more federal or private student lender, even if the lenders have not been designated by The Salon Professional Academy as “preferred lenders”.
Federal and Private Comparisons
When The Salon Professional Academy provides information on loans from private lenders to students, we will also provide each student with a written separate reminder of the potential availability of federal student loans. We will also offer a written comparison of the principal terms of the private loans to the principal terms of federal student loans, including interest rates, eligibility conditions, repayment options and terms and origination fees.
Limitations on Student Information Disclosures
The Salon Professional Academy will not disclose any information regarding the financial needs, resources and loan options or considerations of its students to any prospective lender or to any other person or entity without a signed authorization from the specific student or parent (if the student is a minor) or proper documentation proving that the specific student or parent have filed an application with a specific lender. The exception to this rule is any entity or person to which disclosure is authorized under the FERPA statutory and regulatory provisions.
Publication of this Code
A copy of this Code of Conduct Regarding Lender Relationships and Loans will be provided to administrative employees of The Salon Professional Academy a minimum of once a year. Each administrative employee will be required to sign a written certification confirming that they have received and read this policy. This Code of Conduct Regarding Lender Relationships and Loans will also be published in the Student Consumer Handbook, posted on The Salon Professional Academy’s website, and a printed copy will be provided to all students upon request.
