The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher
education to develop and enforce a code of conduct that prohibits conflicts of interest
for financial aid personnel. In compliance with this requirement, Glendale Community
College has created the following code of conduct based on the HEOA of 2008:
Other college employees, officers and agents with responsibilities in respect to educational
loans must also comply with this policy.
Ban on Revenue-Sharing Arrangements – Glendale Community College shall not enter into any revenue-sharing arrangement
with any lender or other vendor working with the Financial Aid Office. The college
shall not accept any fee or other material benefit in exchange for recommending a
lender to its
students.
Gift Ban – No Glendale Community College officer or employee with financial aid responsibilities
shall solicit or accept a gift (e.g., a gift of services, transportation, lodging
or meals, provided by purchase of a ticket, payment in advance or reimbursement) having
a monetary value of more than a nominal amount from lenders, guarantors or servicers
of education loans.
Contracting Arrangements Prohibited – No Glendale Community College officer or employee with financial aid responsibilities
shall accept from any lender or lender affiliate any payment or other financial benefit
as compensation for any type of consulting arrangement or other contract to provide
services to a
lender.
Interaction with Borrowers – Glendale Community College shall not automatically assign a particular lender to
any borrower and shall not refuse to certify or delay certification of any loan based
on the lender or guarantee agency selected.
Prohibition on Offers of Funds for Private Loans – Glendale Community College shall not request or accept from any lender an offer
of funds to be used for private education loans in exchange for the college providing
the lender with a specified number or volume of loans made or in exchange for
placement on a preferred lender list.
Ban on Staffing Assistance – Glendale Community College shall not request or accept from any lender any assistance
with call center staffing or financial aid office staffing. Lenders, however, may
provide professional development training to financial aid administrators, educational
advising materials to borrowers or assistance in state or federally-declared natural
disasters.
Advisory Board Assistance – All Glendale Community College employees with financial aid responsibilities shall
be prohibited from receiving anything of value from a lender or guarantor in return
for service on its advisory board. Reimbursement for reasonable expenses incurred
in connection with such service, however, is permitted.
