Skidmore College Student Loan Code of Conduct

The purpose of this Code of Conduct is to ensure that all employees involved in the affairs of the Financial Aid Office understand their obligations to protect the rights and serve only the interests of students and parents. To comply with the 2008 Higher Education Opportunity Act (HEOA), enacted August 14, 2008, Skidmore adopts the following Student Loan Code of Conduct to serve as formal guidance in insuring the integrity of the student aid process and ethical conduct of Skidmore employees in regard to student loan practices.

Revenue Sharing

Revenue-sharing arrangement per the 2008 Higher Education Opportunity Act means any arrangement between an institution and lender, which the lender makes Title IV loans to students or to the families of such students. 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, an office or employee of the institution. Skidmore College and its employees will not enter into any type of revenue-sharing arrangement with any lender.

Gifts

Employees from the Financial Aid Office (or others as noted above) are prohibited from soliciting or accepting any gifts from lenders, guarantors or servicers of educational loans. Per the 2008 HEOA, a gift is any gratuity, favor, discount, entertainment, hospitality, loan, or other item having monetary value of more than a de minimums amount. This includes a gift of services, transportation, lodging or meals, purchase of a ticket, payment in advance, or reimbursement after the expense has incurred.

Contracting Arrangements

Employees of the Financial Aid Office (or others as noted above) may not accept from a lender, or affiliate of any lender any fee, payment, or other financial benefit 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.

Borrower Choice

The Financial Aid Office may not assign a borrower's student loan to a particular lender. The borrower will be responsible for deciding who to borrow his/her loan through after review of lender benefits and services. Skidmore 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

Skidmore College will not request or accept from any lender any offers to be used for private education loans, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans made, insured or guaranteed, a specified loan volume, or a preferred lender arrangement.

Staffing Assistance

Skidmore College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing.

Advisory Board Compensation

Employees of the Financial Aid Office (or others as noted above) who serve on advisory board, commission, or group established by lender, guarantor, or group of lenders or guarantors, are prohibited from receiving anything of value from the lender, guarantor, or group of lenders, except for reimbursement for reasonable expenses incurred by the employee for serving on the advisory board, commission or group.

In addition to the above, employees involved in the affairs of the Financial Aid Office sign Skidmore College's Conflict of Interest Policy and Disclosure Form.