NorthWest Arkansas Community College

Code of Conduct for Educational Loans

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As required by the Higher Education Opportunity Act, NorthWest Arkansas Community College adheres to the following Code of Conduct. This Code of Conduct applies to the officers, employees, and agents of the institution.

Code of Conduct Provisions:

1. NWACC, its officers, employees, or agents will enter into no revenue sharing arrangements with any lender.
2. No officer or employee of NWACC's financial aid office (or an employee or agent who otherwise has responsibilities with respect to educational loans) may solicit or accept a gift, from a lender, guarantor, or servicer of educational 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.
3. No officer or employee of NWACC's financial aid office or employee or agent who otherwise has responsibilities with respect to educational loans, may accept from a lender or an affiliate of 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. NorthWest Arkansas Community College shall not assign any first time borrower through award packaging or other methods, to a particular lender. NWACC shall not refuse to certify, or delay certification of any loan based on the borrower’s selection of a particular lender or guaranty agency.
5. NWACC shall not request or accept from any lender any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for NWACC providing concessions or promises regarding providing the lender with a specific number of title IV loans made, insured, or guaranteed, a specific loan volume, or preferred lender arrangement.
6. NWACC shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing. However, certain assistance is permitted such as professional development training for financial aid administrators. Additionally, providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing the materials is permitted. Staffing services on a short-term, non recurring basis to assist NWACC with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, federally declared national disasters, or other localized disasters and emergencies identified by the Secretary is allowed.
7. Any employee in the financial aid office at NWACC, or who otherwise has responsibilities with respect to education loans or other student financial aid at NWACC, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group o 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.