Student Lending Code of Conduct

The Higher Education Opportunity Act of August 14, 2008, requires that campuses participating in federal Title IV student aid programs publish a code of conduct, serving as the formal guiding principles in ensuring the integrity of the student loan process and ensuring the ethical conduct of Davidson College employees in regard to student loan practices.

We participate in the William D. Ford Federal Direct Loan program through the United States Department of Education. This program includes Direct Subsidized, Direct Unsubsidized, and Direct Parent PLUS loans.

Private/Alternative Education loans are also processed for students at their request as needed.

We do not maintain a preferred lender list for private/alternative student loans nor do we recommend any private lender. All decisions concerning private education loans will be made by you, the borrower, based on your independent review of lender benefits and services. We will not refuse to certify or delay certification of any private/alternative education loan based on your selection of a particular lender.

To avoid any conflict of interest with the responsibilities of our employees with respect to parent, student, and private/alternative loans, the Davidson College Student Lending Code of Conduct prohibits the following:

• Revenue sharing arrangement with any lender. We will not promote or recommend any lender in exchange for a fee or other material benefit from a lender.
• The solicitation or acceptance of gifts from a lender, guarantor or servicer by anyone with responsibilities with respect to loans at the institution. This prohibition extends to our staff members' families (including staff members and spouses; parent and stepparent; sibling or step- sibling; child or step-child; and grandchild or step-grandchild; as well as the child's spouse and sibling's spouse).
• Employees or agents of a lender from identifying themselves as our employee, whether directly or by implication, to students, parents or any person seeking information about Davidson College.
• The assignment of a first-time borrower's loan to a particular lender, or refusing to certify/originate or otherwise delay certification/origination of any loan, regardless of the lender or guaranty agency the borrower selects.
• The acceptance of any funds to be used for private/alternative education loans in exchange for the institution providing concessions to the private lender.
• Requesting or accepting assistance with financial aid office staffing from any lender.
• Any employee with responsibilities with respect to financial assistance at the institution who serves on an advisory board or commission of a lender or guarantor may not accept anything of value from the lender or guarantor, except reimbursement for the reasonable expenses of serving on the board or commission. A financial aid office staff member wishing to serve on an advisory board must seek prior approval from his or her supervisor.

Staff members should understand and adhere to all institutional policies and any local, state and federal requirements that are applicable to their conduct or job performance. Any staff member who has a question whether a particular situation or activity creates a conflict of interest or violates any laws or policy should immediately notify their supervisor prior to committing such activity or at the earliest time when such question arises.