Arapahoe Community College (ACC) is committed to providing educational resources to students, families and the community to meet their educational goals. This commitment requires providing accurate service to our constituents, while remaining accountable for Federal, state, institutional and private financial aid funds.
To ensure trust in the ACC’s administration of financial resources to help students fund their education, all officers, employees and agents of the institution, including without limitation individuals who are employed in the financial aid office or who otherwise have responsibilities with respect to education loans, are required to abide by the following code of conduct, per 34 C.F.R. § 668.14(b)(27) in the Federal Code of Regulations:
- ACC shall not enter into any revenue sharing arrangements with a lender. Revenue sharing is any arrangement in which a lender pays a fee or provides other material benefits, including revenue or profit sharing, to the University or to its officers, employees, or agents, in exchange for recommending the lender or the loan products of the lender.
- No officer or employee of the ACC Financial Aid Office (or an employee or agent who otherwise has responsibilities with respect to education loans) shall solicit or accept gifts from a lender, guarantor, or servicer of education loans. For purposes of this policy, a gift to a family member of an officer or employee or to any other individual based on that individual’s relationship with the officer or employee, shall be considered a gift to the officer or employee if the gift is given with the knowledge and acquiescence of the officer or employee and the officer or employee has reason to believe the gift was given because of the official position of the officer or employee.
- No officer or employee of the ACC Financial Aid Office (or employee or agent who otherwise has responsibilities with respect to education loans) shall accept from a lender, or an affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
- ACC shall not assign, through the award packaging or other methods, a first-time borrower’s loan to a particular private lender. In addition, the institution shall not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty.
- ACC shall not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of federal loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement.
- ACC shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training consistent with state governmental ethics statutes, educational counseling materials (as long as the materials identify the lender that assisted in preparing the materials), and staffing services on a short-term, nonrecurring basis during emergencies or disasters. Employees of lenders must be directed to identify themselves as employees of the lender and to never identify themselves as ACC employees when meeting or speaking with students or parents.
- No employee of the ACC Financial Aid Office (or any employee who otherwise has responsibilities with respect to education loans or financial aid) shall receive anything of value for serving on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors).
- The ACC Financial Aid Office shall:
- provide student and parent borrowers with access to, and process loans for, all lenders of choice, including those not on a ‘lender list’
- offer the maximum federal aid eligibility and recommend that borrowers explore the benefits of federal financial aid before processing private/alternative loans
- provide ‘exit counseling’ to educate borrowers on their rights and responsibilities and provide information to enable them to determine which repayment option best fits their individual financial needs
- provide comprehensive financial aid counseling for students, prospective students, families and the community
- The ACC Financial Aid Office shall communicate to its constituents:
- established priority dates, deadlines, and eligibility criteria via its website, email, publications, and presentations
- the need to complete and submit required documents in a timely manner via email and the ACC’s student information system (MyACC)
- information regarding relationships with lenders and the criteria and process used to select lenders on any lender lists
- the right and ability of borrowers to select a lender of their choice regardless of any lender list
- Violations of this policy may result in disciplinary action, up to and including dismissal of employees, or termination of agent relationships.