Student Loan Code of Conduct

Wayne County Community College District (WCCCD) participates in the William D. Ford Direct Loan Program. To comply with the Higher Education Opportunity Act (HEOA), WCCCD adopts this Student Loan Code of Conduct for all employees regarding student loan practices and administration.

1. WCCCD and its employees will not enter into any revenue-sharing arrangement with any lender, guarantor, or servicer.  “HEOA defines revenue-sharing” arrangement as any arrangement between an institution and a lender under which the lender makes Title IV loans to students attending the institution or to the families of those 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, its officers, employees, or agents.  WCCCD does not utilize preferred lenders.   Students are permitted to select lenders of their choice without WCCCD recommendations.
   
   
2. Financial Aid Office employees and all other departments with any responsibility concerning student loans are prohibited from accepting or soliciting gifts from a lender, guarantor or loan servicer.  A gift is any gratuity, favor, discount, entertainment, hospitality or loan of more than a token value.   Gifts to a WCCCD employee's family members are considered gifts to the employee if such gifts were given because of the employee’s official position with WCCCD.  Gifts do not include a brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy.
   
   
3. No WCCCD employee with responsibilities related to student loans shall enter into a contract arrangement with a lender or lender affiliate. No such employee may accept from any lender or lender affiliate any fee, payment, or other financial benefit as compensation for any consulting arrangement or contract to provide services to or on behalf of a lender relating to student loans.
   
   
4. WCCCD participates in the William D. Ford Federal Direct Loan program, which provides student loans through the U.S. Department of Education. WCCCD does not utilize preferred lenders for the private student loan sector. WCCCD will not steer students toward any particular private lender nor delay the certification of such loans. 
   
   
5. WCCCD does not assign first-time borrowers’ student loans to any particular lender through award packaging or any other method. As a Direct Loan participant, loans are provided through the U.S. Department of Education. 
   
   
6. WCCCD will not request or accept from any lender, guarantor, or servicer any offer of funds for private student loans, including funds for an opportunity pool loan, to students in exchange for concessions or promises to the lender, guarantor, or servicer for a specific number or volume of student loans, or a preferred lender arrangement.  An “opportunity pool loan” is defined by HEOA as a private education loan made by a lender to a student (or the student’s family) that involves a payment by the institution to the lender for extending credit to the student.
   
   
7. WCCCD will not request or accept assistance with call center or financial aid office staffing from any lender, guarantor, or servicer of student loans. The exception is that a lender may provide professional development training, educational counseling materials, assistance to borrowing students regarding specific processes, and other services provided on behalf of WCCCD.

Any WCCCD employee with responsibilities related to student loans may serve on the advisory board, commission, or group established by a lender(s) or guarantor(s).  That employee is prohibited from receiving anything of value from the lender(s), guarantor(s), or group except for the reimbursement of reasonable expenses incurred in carrying out the duties of serving on the board.