The Higher Education Opportunity Act requires institutions of higher education participating in the administration of educational loan programs to develop and publish a Code of Conduct (34 CFR 601.21).
- The CJC Financial Code of Conduct
The California Jazz Conservatory (CJC) expects the highest levels of professionalism and ethical behavior from all officers, employees, and agents whose responsibilities include student financial aid matters. These individuals must avoid even the appearance or perception of any conflict of interest regarding their student aid responsibilities. They must refrain from taking any action they believe is contrary to law, regulation, or the best interest of the students they are serving, and must disclose all conflicts identified in this policy.
Any CJC officer, employee, or agent who has responsibilities with respect to student educational loans is required to comply with this Code of Conduct as outlined below.
- The CJC does not enter into any revenue-sharing arrangement with any lender.
- No officer, employee or agent of the CJC who is employed in the financial aid office or who otherwise has responsibilities with respect to education loans, will solicit or accept any gift or other thing of value from a lender, guarantor, or servicer of education loans.
- Certain items provided or contributed by lenders are not considered gifts, such as training materials for staff, entrance and exit counseling services including providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials.
- No officer, employee or agent of the CJC who is employed in the financial aid office or who otherwise has responsibilities with respect to education loans, will 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.
- The CJC will not, for any first-time borrower, assign, through award packaging or other methods, the borrower’s loan 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.
- The CJC will 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 campus providing concessions or promises regarding providing the lender with a specified number of loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement for such loans.
- The CJC does not request or accept from any lender any assistance with call center staffing or financial aid office staffing.
- No employee of the CJC 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, will receive anything of value from the lender, guarantor, or group of lenders or guarantors for such service.