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Code of Conduct

Schools participating in Title IV loan programs are required to develop and adhere to a code of conduct.

The following code of conduct includes requirements specified in the Higher Education Act and applies to officers, employees, and agents of Martin Luther College.

  1. The college will not engage in revenue-sharing arrangements with any lender. This is defined as any arrangement between a school and a lender that results in the lender paying a fee or other benefits, including a share of the profits, to the school, its officer, employees or agents, as a result of the school recommending the lender to its students or families of those students.
  2. Employees in the Financial Aid Office will not accept gifts from any lender, guaranty agency or loan servicer. This ban is not limited to providers of Title IV loans. Providers of private education loans, also known as alternative loans, are included in this provision. The law does provide for some exceptions related to specific types of activities or literature including:
    1. Brochures or training material related to default aversion or financial literacy.
    2. 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.
    3. Favorable terms and benefits to a student employed by the college as long as those same terms are provided to all students at the college.
    4. Entrance and exit counseling as long as the college’s staff is in control and the services of a specific lender are not promoted.
    5. Philanthropic contributions from a lender, guarantee agency, or servicer unrelated to educational loans.
    6. State education, grants, scholarships, or financial aid funds administered by or on behalf of the State.
  3. No employee of the college’s financial aid office will accept any fee, payment or financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
  4. Borrowers will not be steered to particular lenders, or delay loan certifications. This includes assigning any first-time borrower’s loan to a particular lender as part of their award packaging or other methods.
  5. The college will not request nor accept any offer of funds for private loans. This includes any offer of funds for loans to students at the college, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans, or inclusion on a preferred lender list.
  6. The college will not request nor accept any assistance with call center staffing for financial aid office staffing. However, the college can request or accept assistance from a lender related to:
    1. Professional development training for financial aid administrators.
    2. 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.
    3. 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.
  7. No employee of the institution may receive anything of value from a lender, guarantor, or group in exchange for serving in this capacity. Employees may, however, accept reimbursement for reasonable expenses incurred while serving in this capacity.
  8. The college will not permit a lender to use any form of identification related to Martin Luther College on lender promotion materials.

Martin Luther College's Title IV Loan Code of Conduct was adopted by its Administrative Council on June 29, 2009.