Title IV Loan School Code of Conduct Policy

Schools participating in any of the Title IV loan programs are required by the Department of Education to develop, publish, and enforce a code of conduct. All members of the Westminster Theological Seminary Financial Aid Department adopt this Code of Conduct use it to govern interactions between the seminary and lenders to ensure that these relationships are for the best interest of our students.

Ban on Revenue Sharing Agreements

Westminster Theological Seminary nor any of its officers, employees, or agents will enter into any revenue sharing arrangements which are defined by the Higher Education Opportunity Act of 2008, amending the Higher Education Act of 1965, as any arrangement between the institution and a lender where, as a result of the institution recommending a lender to its students or families of such students, the lender pays a fee or provides other material benefits, including revenue or profit sharing to the institution or agent.

Ban on Gifts

The Financial Aid Department must not solicit or accept any gift from a lender, guarantor, or loan servicer. For purposes of this Code, 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. The HEOA provides some exceptions from its definition of “gift” including the following:

• Standard material, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy such as a brochure, a workshop, or training.

• Food, training, or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training.

• Favorable terms and benefits to a student employed by the institution as long as those same terms are provided to all students at the institution.

• Entrance and exit counseling as long as the institution’s staff are in control, and they do not promote the services of a specific lender.

• Philanthropic contributions from a lender, servicer, or guarantor or any contribution from a lender, servicer, or guarantor that is not made in exchange for any advantage related to education loans.

• State education grants, scholarships, or financial aid funds administered by or on behalf of a State

For purposes of this Code, a “gift” to a family member or an agent, or to any individual based on that individual’s relationship with the agent, is considered a gift if:

• The gift is given with knowledge and approval of the agent and

• The agent has reason to believe the gift was given because of the official position as an agent.

Ban on Contracting Agreements

The Financial Aid Department will not accept from any lender or its affiliates 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.

Ban on Steering Borrowers

The Financial Aid Department will not assign first time borrowers, via award packaging or other methods, to a particular lender or refuse to certify or delay certification of any loan based on the borrower’s selection of a particular lender or guaranty agency.

Ban on Offers or Funds for Private Loans

The Financial Aid Department will not request or accept from any lender any offer of funds to be used for private education loans. This prohibition includes any offer for an opportunity pool loan to students in exchange for providing the lender with a specified number of loans, a specified loan volume on such loans, or a preferred lender arrangement for such loans.

Ban on Staffing Assistance

The Financial Aid Department will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. However, the HEOA does not prohibit institutions from requesting or accepting assistance from a lender related to the following:

•Professional development for financial aid administrators.

•Provision of educational counseling materials, financial literacy materials, or debt management materials to borrowers as long as the materials provided disclose to the borrower the identity of any lender that assisted in preparation of the materials.

•Staffing services on a short-term, nonrecurring basis to assist the school with financial-aid related functions during emergencies, including State-declared or federally-declared natural disasters, and other localized disasters and emergencies identified by the Secretary.

Ban on Advisory Board Compensation

The Financial Aid Department will not receive anything of value from a lender, guarantor, or group in exchange for serving on an advisory board. They may, however, be reimbursed for reasonable expenses incurred while serving in this capacity.

For more information on this policy and similar policies, please visit Federal Student Aid.