To avoid conflicts of interest with outside agencies and other affiliations related to financial aid programs including student loans, Pasadena City College (PCC) has established an ethical framework for professional behavior and responsibilities. The Higher Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid personnel.

PCC’s Code of Conduct prohibits all employees who work in the Financial Aid Office and all other school employees, officers, and agents who have responsibilities with respect to education loans:

A revenue-sharing arrangement with any lender.

All employees are banned from participating in a “revenue-sharing arrangement” between the institution and lender, under which the lender makes Title IV loans to students attending the institution.

Receiving gifts from a lender, guaranty agency, or loan servicer while employed by the financial aid office.

No financial aid officer or employee of the institution may solicit or accept any gift from a lender, guarantor, or servicer of education loans.

Contracting arrangements.

No officer or employee of the institution’s financial aid office may 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 service to or on behalf of a lender relating to education loans.

Steering borrowers to particular lenders or delaying loan certifications.

For any first-time borrower, an employee of the institution’s financial aid office may not assign, through the award packaging or other methods, the borrower’s loan to a particular lender.

Offers of funds for private loans.

The institution may 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 Title IV loans made, insured, or guaranteed

Staffing assistance.

The institution may 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 and educational counseling materials.

Advisory board compensation.

Any employee of the institutions financial aid office who serves on an advisory board, commission, or group established by a lender or guarantor is prohibited from receiving anything of value from the lender, guarantor, or group.