Code of Conduct for Education Loans
Student Loan Code of Conduct
MCTC has adopted this Student Loan Code of Conduct to serve as the formal guiding
in ensuring the integrity of the student aid process and ethical conduct of employees in regard to student loan practices. The Student Loan Code of Conduct applies to all employees who work in
the Office of Financial Aid and all other College employees, including agents of the College who
have responsibilities related to educational loans or other forms of student financial aid. The Student Loan Code of Conduct has been established to meet the requirements contained in the
2008 Higher Education Opportunity Act. Items in this Code of Conduct provide additional standards of conduct for employees with responsibility for student financial aid and do not
replace any existing or future requirements imposed by State of Kentucky or KCTCS related to
codes of conduct, conflict of interest policies, ethics training, or other such requirements.
The Student Loan Code of Conduct also confirms that MCTC does not have preferred lender
arrangements of any kind or a preferred lender list.
The College and its employees will not enter into any type of revenue-sharing arrangement
any lender, guarantor or servicer.
Employees of the Office of Financial Aid and Scholarships are prohibited from soliciting
accepting any gift from a lender, guarantor, or servicer of education loans. Gifts include any
gratuity, favor, discount, entertainment, hospitality, loan or other item. This includes a gift of
services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket,
payment in advance, or reimbursement after the expense has incurred. Gifts to family members
of a College employee are considered to be a gift to the employee if the gift is given with the
knowledge and consent of the employee and there is reason to believe the gift was given because of the official position of that employee.
Employees of the Office of Financial Aid and Scholarships shall not accept from any
affiliate of any lender any fee, payment or other financial benefit (including opportunity to
purchase stock) as compensation for any consulting arrangement or other contract to provide
services to a lender or on behalf of a lender relating to education loans.
Preferred Lender Status
MCTC participates in the William D. Ford Federal Direct Loan Program which provides
and parent loans through the U.S. Department of Education. Lenders in the private student loan
industry will not be given a preferred status. MCTC does not have any preferred lender
arrangements that give any lender an advantage in securing business from our students. The
College does not provide students a preferred lender list from which to select a lender for a
private student loan. All loans are processed without regard to lender or mode of transmission
(i.e., electronic or paper). MCTC will neither recommend a private loan lender nor accept
material benefits including revenue or profit sharing to the institution, an officer, or an employee
of the institution or an agent.
Private Loan Certification
The College will not assign a borrower's private student loan to a particular lender;
will be made by the borrower in his/her independent review of borrower benefits and lender
services. The College will not refuse to certify, or delay certification of, any loan based on the
borrower's selection of a particular lender or guaranty agency.
Opportunity Pool Loan
The College will not request or accept from any lender any offer of funds to be used
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 Seminole State providing concessions or
promises regarding providing the lender with (i) a specified number of federal loans made,
insured or guaranteed; (ii) a specified federal loan volume; or (iii) a preferred lender arrangement
for such loans.
MCTC will not request or accept from any lender, guarantor, or servicer of student
assistance with call center staffing or financial aid office staffing.
Advisory Board Compensation
Employees of the Office of Financial Aid who serve on an advisory board, commission
established by a lender, guarantor or group of lenders or guarantors are 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.