Title IV & Code of Conduct
To ensure transparency in the administration of its student financial aid program and to avoid the harm that may arise from actual, potential, or perceived conflicts of interest GBSC adheres to the following code of conduct.
All Officers, employees, and agents of GBSC who have responsibilities with respect to student educational loans must comply with this code of conduct.
Ban on revenue-sharing arrangement with any lender.
Neither GBSC as an institution nor any individual officer, employee or agent is permitted to enter into any revenue sharing arrangements with any lender under which the lender pays a fee or provides other material benefits, including revenue or profit sharing to the school, an officer or employee of the school, or an agent and in exchange, the school recommends the lender or the
lender’s loan products and the lender makes Title IV loans to the student attending the school. Ban on receiving gifts from a lender, guaranty agency or loan servicer.
GBSC does not allow any officer or school employee who is employed in the financial aid office or who has responsibilities with respect to student loans to solicit or accept any gift from a lender, guarantor, or servicer of education loans. For purposes of this prohibition, the term “gift” means any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a minimal amount.
Ban on contracting arrangements.
GBSC does not permit an officer or employee of the financial aid office or an agent who has responsibilities related to education loans to accept any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation from any lender or affiliate for any type of consulting arrangement or other contract to provide services to the lender or on behalf of the lender with regard to education loans.
Prohibition against steering borrowers to particular lenders or delaying loan
certifications.
GBSC does not assign any first-time borrower’s loan to a particular lender through award packaging or any other means. In addition the financial aid personnel will not refuse to certify or delay certification of any loan based on the borrower’s selection of a particular lender or guaranty agency.
Prohibition on offers of funds for private loans.
GBSC does not request or accept funds from any lender for private education loans, including funds for an opportunity pool loan, for students in exchange for providing concessions or promises to the lender regarding a specific number of Title IV loans made, insured or guaranteed, a specified loan volume, or a preferred lender arrangement. An “opportunity pool loan” is defined as a private education loan made by a lender to a student that involves a payment by the institution to the lender for extending credit to the student.
Ban on staffing assistance.
GBSC does not request or accept any assistance with call center staffing or financial aid office staffing from any lender.
Ban on advisory board compensation.
No one employed in the financial aid office or that has any responsibilities with respect to education loans or other student financial aid will receive any material benefit from serving on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors. However, these employees may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.
