Code of Conduct

Sumner College, as a participant in this Title IV Loan program, adopted and enforces a school Code of Conduct with regards to educational loans. This Code is designed to protect student borrowers and ensure they are provided with all of the necessary resources to make an informed decision about their loans. Also prohibits possible conflicts of interest on the part of employees of the institution. This applies to all Sumner College officers, employees, agents including alumni and organizations affiliated with Sumner College. This information must be prominently displayed on the institution’s website and all employees, agents, and officers with responsibilities related to student loans must be annually informed of these provisions of the code of conduct.

All Sumner College officers, employees and agents shall refrain from the following activities:

• Ban on Revenue-Sharing
  Sumner College will not enter into any revenue-sharing arrangements with any lender.

• Gift Ban
  Employees and agents of Sumner College who deal directly with student loans may not accept or solicit any gifts from a lender, guarantor, or student loan servicer. A “gift” could be in the form of: gratuities, favors, discounts, entertainment, hospitality, loan, and other items having a monetary value of more than a de minimus amount.

• Prohibited Consulting/Contracting Arrangements
  No employee of the Financial Aid Office may accept from a lender or affiliate of any lender any fee, payment, or other financial benefit (including stock options) as compensation for any type of consulting arrangement or other contract to provide services to or on behalf of a lender relating to education loans.

• Prohibit Assigning of Lender to First-Time Borrower
  Sumner College may not assign a particular lender to a first-time borrower or refuse to certify a lender of the borrower’s choice.

• Prohibition on Offers of Funds for Private Loans
  Sumner College 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 institution providing concessions or promises regarding providing the lender with specified number of loans, volume, or a preferred lender arrangement for such loans.

• Ban of Staffing Assistance
  Sumner College will refrain from requesting or accepting from any lender any assistance with call center staffing or financial aid office staffing.

• Prohibition on Receipt of Compensation for Advisory Board Service
  No employee of the Financial Aid Office or employees with responsibilities regarding education loans who serves on an advisory board, commission, or group established by a lender, guarantor shall receive anything of value from the lender, guarantor or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.