Code Of Conduct For Lincoln Tech Financial Aid Professionals

A Lincoln Tech financial aid professional is expected to always maintain exemplary standards of professional conduct in all aspects of carrying out their responsibilities, specifically including all dealings with any entities involved in any manner of student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized, or regulated activity. In doing so, a financial aid professional will ensure that:

1. No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.

• Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to school designated individuals to avoid the appearance of a conflict of interest.
• The preferred lender list will be compiled without prejudice and for the sole benefit of the students attending the school. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be fully and publicly disclosed. Borrowers will not be auto assigned to any particular lender.
• A borrower’s choice of a lender will not be denied, impeded, or unnecessarily delayed by the school, even if that lender is not included on the school’s preferred lender list.
• No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or their family), or from any entity, lender, or lender affiliate doing business with or seeking to do business with the school (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).

2. Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.

3. Institutional financial aid offers and/or other institutionally provided materials shall include the following:

• Breakdown of estimated individual Cost of Attendance components, including which are direct costs (billed by the institution) versus indirect costs (not billed by the institution).
• Clear indication of proper grouping of each type of aid offered indicating whether the aid is grant/scholarship, loan, or work program.
• Estimated net price.
• Standard terminology and definitions, using NASFAA’s glossary of terms
• Renewal requirements for each aid type being offered as well as next steps and financial aid contact information.

4. All required consumer information is displayed in a prominent location on the institution’s website(s) and in any printed materials, easily identified and found, and labeled as “Consumer Information”.

5. Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.

The Student Loan Code of Conduct

The Student Loan Code of Conduct applies to all employees at Lincoln Tech, including any agents of Lincoln, who have responsibilities related to educational loans or other forms of student financial aid. This Student Loan Code of Conduct has been established to meet the requirements contained in the 2008 Higher Education Opportunity Act, enacted August 14, 2008.

1. Prohibition of Revenue-Sharing: Lincoln will not enter into any revenue-sharing agreements with any lender. No employee in the financial aid division may enter into a contracting arrangement with a lender. Revenue-sharing is defined to mean any arrangement between an institution and a lender making educational loans wherein the institution recommends the lender or the loan products, and in exchange, the lender pays a fee or provides a service to the institution or its employees.
2. Gift Restrictions: An employee who has responsibilities with respect to education loans, or any of their family members, shall not solicit or accept any gift from a lender, guarantor, or servicer of education loans. For purposes of this prohibition, the term “gift” means any gratuity, favor, discount, entertainment, hospitality, loan, or other items having monetary value.
3. Prohibition on Contracting Arrangements: An employee who has responsibilities with respect to education loans shall not accept from any lender or affiliate of any lender any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.
4. Prohibition on Offers of Funds: Lincoln shall not, through a financial aid offer or other method, assign a first-time borrower’s loan to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
5. Preferred Lender List: Lincoln shall not request or accept any offer of funds to be used for private education loans to students from any lender in exchange for the institution providing concessions or promised to a lender regarding a specified number of loans made, insured, or guaranteed; a specified volume of loans; or a preferred lender arrangement for such loans. Lincoln will not restrict students from selecting a particular lender.
6. Staff Assistance: Lincoln shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing unless those services are short-term and non-recurring, in the event of an emergency or disaster or for office staff professional development.
7. Advisory Board Compensation: Any employee who has responsibilities with respect to education loans or other student financial aid, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, shall be prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors.

These principles must apply throughout the administration of the Title IV programs for which the financial aid professional is responsible. The financial aid professional acts as a steward of the student’s confidential information and therefore must safeguard this information in compliance with the Family Educational Rights and Privacy Act (FERPA). All financial aid employees will be required to certify that they will abide by these principles by reading and signing (clicking the acknowledgement button) the Code of Conduct form. The certification process for each financial aid employee will take place at the beginning of every award year.

There should never be any difference between “ethical” and “best practices”. The ethical practice is the best practice. As a company, Lincoln Tech unequivocally supports the principles and practices described in this Code. When a practice or policy arises that appears in conflict with these principles, it is the obligation of the financial aid professional to bring it to the attention of those responsible within the institution, and to seek a resolution consistent with these principles.