Title IV Loan Code of Conduct

In compliance with the Higher Education Opportunity Act [HEOA § 487(a)(25)], a code
of conduct for the financial aid personnel of Southern New Hampshire University
(hereafter referred to as the University) has been developed and posted.
The following guiding principles shall be effective immediately. These guidelines are
designed to avoid any potential for a conflict of interest between the University, its
students or their parents in the student financial aid process. The University shall take all
reasonable steps to adhere to the following principles in the University’s financial aid
operations:


1) The University nor its employees should receive any personal benefit.


a) Neither the University as an institution nor any individual officer, employee or
agent shall enter into any revenue-sharing arrangements with any lender. The
HEOA defines “revenue-sharing arrangement” as any arrangement between the
University and a lender under which the lender makes Title IV loans to students
attending the University (or to the families of those students), the University
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 University or to its officers, employees, or agents.

b) No officer or employee of the University who is employed in the financial aid office
or who otherwise has responsibilities with respect to education loans, or agent
who has responsibilities with respect to education loans, or any of their family
members, shall 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 de minimus amount. A gift does not include:

i) a brochure, workshop, or training using standard materials relating to a loan,
default aversion, or financial literacy, such as a brochure, workshop or
training,

ii) food, training, or informational material provided as part of a training
session designed to improve the service of a lender, guarantor, or servicer if
the training contributes to the professional development of the University’s
officers, employee or agent,

iii) favorable terms and benefits on an education loan provided to a student
employed by the University if those terms and benefits are comparable to those
provided to all students at the University,

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iv) entrance and exit counseling as long as the University’s staff are in control of the
counseling and the counseling does not promote the services of a specific
lender,

v) philanthropic contributions from a lender, guarantor, or servicer that are
unrelated to education loans or any contribution that is not made in exchange
for advantage related to education loans, and

vi) State education grants, scholarships, or financial aid funds administered by or
on behalf of a State.

c) An officer or employee of the University who is employed in the financial aid office
or who otherwise has responsibilities with respect to education loans, or an agent
who has responsibilities with respect to education loans, shall not accept from
any lender or affiliate of any lender 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 relating to education loans.

2) University employees should not serve on lender advisory boards for remuneration.

a) Any employee who is employed in the financial aid office, or who otherwise has
responsibilities with respect to education loans or other student financial aid, and
who serves on an advisory board, commission,or group established by a lender,
guarantor, or group of lenders or guarantors, shall be prohibited from receiving
anything of value from the lender, guarantor, or group of lenders or guarantors,

b) An employee who is employed in the financial aid office, or who otherwise has
responsibilities with respect to education loans or other student financial aid, and
who serves on an advisory board, commission, or group established by a lender,
guarantor, or group of lenders or guarantors may be reimbursed for reasonable
expenses incurred in serving on such advisory board, commission, or group.

3) The University should not provide any advantage to a Lending Institution.

a) The University shall not:

i) for any first-time borrower, assign, through award packaging or other
methods, the borrower's loan to a particular lender; or

ii) refuse to certify, or delay certification of, any loan based on the borrower's
selection of a particular lender or guaranty agency.

b) The University shall not request or accept from any lender any offer of funds to be
used for private education loans, including funds for an opportunity pool loan,
to students in exchange for the University providing concessions or promises
regarding providing the lender with:

i) a specified number of loans made, insured, or guaranteed under Title IV;

ii) a specified loan volume of such loans; or

iii) a preferred lender arrangement for such loans

4) The University shall not accept staffing assistance.

a) The University shall not request or accept from any lender any assistance with call
center staffing or financial aid office staffing,

b) An exception is a lender may provide professional development training,
educational counseling materials (as long as the materials identify the lender that
assisted in preparing the materials), or staffing services on a short-term,
nonrecurring basis during emergencies or disasters.

5) The University should make appropriate use of any Preferred Lender Lists.

a) If the University decides to promulgate a list or lists of preferred or recommended
lenders for student loans or similar ranking or designation (“Preferred Lender
List”), the selection of Lending Institutions for inclusion on the Preferred Lender
List shall be made with care and without prejudice for the sole benefit of
students and the families and without regard to the financial interests of the
University.

b) In compiling, maintaining, and making available the preferred lender list, the
University shall:

i) Disclose detailed information about the terms and conditions of the loans
offered by preferred lenders,

ii) Disclose why it entered into an arrangement with each lender, particularly
with respect to terms and conditions or provisions favorable to the borrower.

iii) Disclose that students do not have to borrow from a lender on the preferred
lender list,

iv) Ensure that the list contains at least three unaffiliated lenders for the Title IV
loans and at least two unaffiliated lenders for private education loans. The
list must specifically indicate whether a lender is or is not an affiliate of each
other lender on the list. If a lender is an affiliate of another lender, the
University must describe that affiliation,

v) Prominently disclose the method and criteria used in selecting the lenders,

vi) Not deny or impede the borrower’s choice of a lender or unnecessarily delay
certifying a Title IV loan for a borrower who chooses a lender not on the list