TITLE IV LOAN
CONFLICT OF INTEREST POLICY AND CODE OF CONDUCT
- Hope College (the College) prohibits revenue-sharing arrangements
with any lender. This is defined as any arrangement
between the College and a lender that results in the lender paying
a fee or other benefits,
including a share of the profits, to the
College, its officers, employees or agents, as a result of the College
recommending the lender to its
students or families of those students.
- The College prohibits its employees of the Office of Financial
Aid from receiving gifts from any lender, guaranty
agency or loan servicer. This is not limited just to those providers
of Title IV loans. The statutory
language refers to lenders of “educational
loans” thus private
education loans offered to students at the College
are covered in this provision as well. The law does
provide for some exceptions related to
specific types of activities or literature. This
a. Brochures or training material related to default aversion or financial
b. Food, training or informational materials as part of training as long
as that training contributes to the professional development of those
individuals attending the training.
c. Favorable terms and benefits to the student employed by the College
as long as those same terms are provided to all students at the College.
d. Entrance and exit counseling
as long as the College’s
staff are in control and they do
not promote the services of a specific
e. Philanthropic contributions from a lender, guaranty agency or servicer
unrelated to education loans.
f. State education, grants, scholarships, or financial aid funds administered
by or on behalf of the State.
- The College prohibits contracting arrangements whereby
any employee of the College’s Office of Financial Aid may not accept
any fee, payment or financial benefit as compensation for any type
arrangement or contract to provide services to or on behalf of a lender
relating to education loans.
- The College prohibits the steering of borrowers to particular
lenders, or delaying loan certifications. This includes assigning
borrower’s loan to a particular lender as part of their award packaging
or other methods.
- The College prohibits offers of funds for private loans.
The College will not request or accept such offers. This includes
any offer of funds
for loans to students at the College, including funds for an opportunity
pool loan, in exchange for providing concessions or promises to the
lender for a specific number of loans, or inclusion on a preferred
- The College prohibits staffing assistance from a lender.
The College will not request or accept any assistance with call
center staffing or
financial aid office staffing. However, the law does not prohibit
the College from requesting or accepting assistance from a lender
a. Professional development training for financial aid administrators.
b. Providing educational counseling materials, financial literacy materials,
or debt management materials to borrowers, provided that such materials
disclose to borrowers the identification of any lender that assisted
in preparing or providing such materials.
c. Staffing services on a short-term, non-reoccurring basis to assist
the College with financial aid- related functions during emergencies,
including State-declared or federally declared natural disasters, and
other localized disasters and emergencies identified by the U.S. Secretary
- The College prohibits advisory board compensation. Employees
of the College may not receive anything of value from a lender,
group in exchange for serving in this capacity. They, may,
however, accept reimbursement for reasonable expenses incurred
while serving in this