Ozarks Technical Community College is committed to an ethical and data-informed perspective on student loans. In affirmation of this commitment, and to avoid conflicts or the appearance of conflicts of interest, employees of the college are bound by the following Code of Conduct:
- Ozarks Technical Community College (referred to hereafter as “OTC”) shall not enter any revenue-sharing arrangements with any lender. A revenue-sharing arrangement is defined as an arrangement between an institution and a lender under which:
- The lender provides or issues private education loans to students attending the institution (or to the families of those students); and
- The institution recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other material benefits, including revenue or profit-sharing, to the institution or to its officers, employees, or agents.
- OTC employees with duties related to private education loan administration may not solicit or accept any gift from a lender, guarantor, or servicer of education loans.
A gift is defined as any gratuity, favor, discount, entertainment, hospitality, loan, or other item having monetary value of more than a de minimus amount. The term gift also includes services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or by reimbursement.
The term gift does not include the following:- Standard material, activities, or programs pertaining to financial literacy
- Food, refreshments, or training that are part of a training session to improve service if training contributes to professional development of the agent.
- Favorable terms, conditions, and borrower benefits on a private education loan provided to a student employed by the college if terms are comparable to those provided to all students.
- Entrance/exit counseling if school staff are in control and counseling does not promote the products or services of any specific lender.
- Philanthropic contributions from a lender, servicer or guarantee agency which are not related to or made in exchange for any advantage related to private education loans.
- State education grants, scholarships, or financial aid funds administered on behalf of a State.
- OTC employees with duties related to private education loan administration may not accept from any lender or affiliate of any lender anything of financial value, such as a 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 or on behalf of a lender relating to private education loans.
- OTC employees may not direct a borrower toward a particular lender or assign a first-time borrower to a particular lender or servicer. OTC may not delay or refuse certification of any loan based on the borrower’s lender or guaranty agency selection.
- OTC employees must not request or accept funds from any lender for private education loans, including funds for an opportunity pool loan, to students in exchange for promises of a specific number of private education loans, loan volume, or a preferred lender arrangement.
An opportunity pool loan means a private education loan that involves a payment, directly or indirectly by the institution, of points, premiums, additional interest or financial support to the lender for the purpose of the lender extending credit to the student.
OTC shall not request or accept from any lender any assistance with call center or financial aid office staffing, except to provide:- Professional development training for aid officers.
- Counseling, financial literacy, or debt management materials for borrowers as long as materials disclose that the lender prepared or provided the materials
- Staffing on a short-term, nonrecurring basis to assist with aid-related functions during an emergency.
- OTC employees with duties related to private education loan administration and who serve on an advisory board, commission, or group established by a lender or guarantor, may not receive compensation, except for reimbursement for reasonable expenses incurred.
Employees of the OTC Student Financial Aid office shall be made aware of this Code of Conduct annually.