Financial Aid Code of Conduct

The Higher Education Opportunity Act regulates the conditions under which educational institutions may participate in Title IV programs. Under HEOA 487(a)(25) participating educational institutions are required to develop and comply with a code of conduct prohibiting conflicts of interest involving its financial aid personnel. In compliance with federal law, Ensign College’s officers, employees and agents are required to comply with the provisions of this code of conduct and avoid real or perceived conflicts of interest.

1. Neither Ensign College as an institution nor any individual officer, employee or agent shall enter into any revenue-sharing arrangement with any lender.
2. No officer or employee of Ensign College who is employed in the financial aid office or who otherwise has responsibilities with respect to education loans, or agent who has responsibilities with respect to education loans, or any of their family members, shall 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, transportation, lodging, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount.
3. An officer or employee of Ensign College who is employed in the financial aid office or who otherwise has responsibilities with respect to education loans, or agent who has responsibilities with respect to education loans, shall not accept from 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. Ensign College shall not:
   1. Assign, through award packaging or other methods, the loan of any first-time borrower to a particular lender; or
   2. Refuse to certify, or delay certification of, any loan based on a borrower’s selection of a particular lender or guarantee agency.
5. Ensign College shall not request or accept from any lender any offer of funds to be used for private education loans (as defined in section 140 of the Truth in Lending Act), including funds for an opportunity pool loan, to students in exchange for the College providing concessions or promises regarding providing the lender with:
   • A specific number of loans made, insured, or guaranteed under this title;
   • A specific loan volume of such loans; or
   • A preferred lender arrangement of such loans.
6. Ensign College shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing.
7. Any employee who is employed in the Financial Aid Office, or who otherwise has responsibilities with respect to education loans or other student financial aid of the College, 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, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group; provided that the employee makes a complete disclosure to the College administration. If any such reimbursements are made, the Ensign College must report to the Department of Education on an annual basis the amount of such reimbursements, the employee’s name, the date of the reimbursement, and a brief description of the activity for which the reimbursement was paid as described in section 140(d) of the Truth in Lending Act.