Student Loan Code of Conduct for CLC Officials

CLC will not solicit or accept anything of value from any lender, guarantor or servicer in exchange for any advantage or consideration provided by the lending institution related to its student loan activity. This prohibition covers, but is not limited to:

1. revenue-sharing arrangements;
2. any computer hardware for which CLC pays below market prices;
3. any computer software used to manage loans, unless the software can manage disbursements from all lenders; and
4. any printing costs, postage or services.

This does not prevent CLC from soliciting or accepting favorable terms and conditions where the benefit is made directly to student borrowers.

CLC officers, employees and agents are prohibited from soliciting or accepting any gift, gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than a de minimus amount from a lender, guarantor or servicer of educational loans.

This prohibition includes, but is not limited to, services, transportation, lodging or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.

This does not preclude any CLC officer, employee or agent from receiving compensation for conducting non-college business with a lender, guarantor or servicer, or from accepting compensation that is offered to the general public.

This prohibition does not prevent CLC from holding membership in any non-profit professional associations.

The following items are not considered "gifts:"

1. materials or programs on issues related to loans, default aversion, default prevention or financial literacy;
2. food, refreshments, training or informational material furnished to any officer, employee or agent as an integral part of a training program designed to improve the service of a lender, guarantor, or servicer of education loans to CLC, if such training contributes to the professional development of the officer, employee or agent;
3. favorable terms, conditions and borrower benefits on an education loan provided to a student employed by CLC if such terms, conditions, or benefits are comparable to those provided to all students;
4. entrance and exit counseling services provided to borrowers, as long as:
   1. the institution's staff maintains control of the counseling; and
   2. the products and services of any lender are not promoted.
5. philanthropic contributions to CLC that are unrelated to education loans and are not made in exchange for any advantage related to education loans;
6. state education grants, scholarships or financial aid funds administered by or on behalf of a State.

Gifts to family members of any officer, employee, or agent of CLC will be considered a gift to said officer, employee or agent if:

1. The gift is given with the knowledge and acquiescence of the officer, employee or agent; and
2. The officer, employee, or agent has reason to believe the gift was given because of the official position of said officer, employee or agent.

CLC officers, employees and agents are prohibited from receiving any remuneration for serving as a member or participant on an advisory board of any lender, guarantor or servicer, or receiving any reimbursement of expenses from said participation.

This does not preclude any officer, employee or agent from participating on a lender advisory board unrelated to student loans.

This does not preclude CLC officers, employees and agents not directly or indirectly involved in the affairs of the college's financial aid office from serving on the board of directors of a publicly traded or privately held company.

CLC officers, employees and agents are prohibited from entering into contracting or consulting arrangements, except:

1. anyone who is not employed in the financial aid office and does not have responsibilities for loans may perform paid or unpaid service on a board of directors of a lender, guarantor or service officer, employee or agent
2. an officer, employee, or agent who is not employed in the financial aid office but does have responsibilities for loans may perform paid or unpaid service on a board of directors of a lender, guarantor or servicer if they recuse themselves, in writing, from decisions involving CLC
3. an officer, employee, or agent of a lender, guarantor, or servicer may serve on the Board of Trustees of CLC if they recuse themselves, in writing, from decisions regarding student lending

CLC will not solicit or accept any offer of funds for private educational loans or opportunity pool loans in exchange for providing a lender with loan volume or a preferred lender arrangement.

CLC will not solicit or accept staffing assistance from any lender, except for:

1. professional development training
2. educational counseling, financial literacy, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials
3. short-term staffing assistance to help CLC during emergencies

CLC participates in the Direct Lending loan program and all student and parent borrowers are packaged under that program. In respect to Direct Lending and/or alternative loans:

1. CLC will not, for any borrower, assign through award packaging or other methods, the borrower's loan to a particular lender
2. CLC will not refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.