Student Loan Code of Conduct

Clarkson University participates in the William D. Ford Federal Direct Loan Program. This program includes the Direct Subsidized and Direct Unsubsidized Students Loans, the Direct Graduate PLUS Loan, and the Direct Parent PLUS Loan. Upon request from students and parents, private loans are also certified and processed for students. To comply with the 2008 Higher Education Opportunity Act, Clarkson University has instituted a Student Loan Code of Conduct to ensure the integrity of the administration of all student loan programs. Clarkson is committed to a fair and equitable process that is committed to the highest standards. To this end, Clarkson adheres to the following principles:

1. Prohibition on Revenue Sharing
   • Clarkson University has instituted a ban on “revenue-sharing arrangements.” The Higher Education Opportunity Act defines a “revenue-sharing arrangement” as any arrangement between an institution and a lender under which the lender (1) makes loans to students attending the institution (or to the families of those students), (2) the institution recommends the lender or the loan products of the lender and, (3) in exchange, the lender pays a fee or provides other material benefits, including revenue or profit-sharing, to the institution, to its officers, employees, or agents.
   • No officer, trustee or employee of the University shall accept anything of value from any lending institution, guarantor, or servicer in exchange for any advantage or consideration sought by the lending institution, guarantor or servicer.
2. Prohibition on Contracting Arrangements
   • No officer, trustee, or employee of the University will accept from any lender, guarantor or servicer any fee, payment or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to or on behalf of a lender, guarantor or servicer.
3. Prohibition on Offers of Funds for Private Loans
   • No officer, trustee, or employee of the University will request or accept from any lender, guarantor or servicer any offer of funds to be used for private educational loans, including funds for an “opportunity pool loan”, to students in exchange for the University providing concessions or promises to the lender, guarantor or servicer for a specific number of Title IV loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement. Prohibited financial benefits include (but are not limited to) revenue-sharing, fees, payments, printing costs or below-cost computer hardware or software, cash, gifts, stocks, expense-paid trips, entertainment, lodging, meals or travel costs.
   • An “opportunity pool loan” is defined as a private education loan made by a lender to a student or parent that involves a payment by the institution to the lender for extending credit to the student.
4. Gift Restrictions
   • Officers, trustees and employees of the University are prohibited from soliciting or accepting any gift from a lender, guarantor, or servicer of educational loans. Gifts include (but are not limited to) any cash, gratuity, favor, discount, entertainment, hospitality, loan, stocks, printing costs, below cost computer hardware or software, expense-paid trips or reimbursement for lodging, meals or travel to conferences or training seminars. Training materials are not considered gifts.
   • The policy regarding Gifts and Gratuities is also located in the Operational Manual – Administrative and Financial Policies and Procedures - 7.21(5)
5. Preferred Lender Lists
   • Clarkson University participates in the William D. Ford Federal Direct Loan Program which provides student and parent loans through the US Department of Education.
   • Clarkson University currently does not utilize a preferred lender list for private educational loans. No lender is given a preferred status or is given any advantage in securing potential borrowers. Students and parents are free to select the lending institution of their choice.
   • Clarkson University will not recommend, select, assign or refer a student to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender. If in the future, Clarkson University institutes a preferred lender list, this code of conduct will be revised to reflect the change.
6. Advisory Board Compensation Rules
   • No Clarkson University employee in the Office of Financial Aid, Student Accounts, Student Administrative Services or an employee who otherwise has responsibilities with respect to educational loans, and who serves on an advisory board, commission, or group established by a lender, guarantor or servicer shall receive anything of value for such service.
7. Staff Assistance
   • Clarkson University shall not request or accept any staff assistance from any lender, guarantor or servicer in the entire Student Administrative Services Area including the Office of Financial Aid and the Call Center.