May 2009
This code of conduct applies to all employees of Concordia Theological Seminary (CTSFW), Fort Wayne, Indiana, officers and agents; particularly to all who have responsibilities with respect to Federal Student Aid and student loans.
Concordia Theological Seminary (CTSFW) will not:
- assign lenders to first time borrowers;
- cause unnecessary loan certification delays for lenders not on the preferred lender list. However, some delays may occur when a lender is selected that does not have suitable technical compatibility with our normal loan processing;
- choose lenders for the preferred lender list that have offered or provided inducements to this school.
CTSFW prohibits the following activities:
- All revenue sharing between lenders and this institution (loan volume in exchange for money or gifts)
- Financial aid employees and their family members receiving gifts* from lenders or guarantors or servicers
- Contracting between school employees and lenders
- Opportunity pool loans
- Staffing assistance provided by lenders
- Printing costs or services provided by lenders
- Delaying loan certification based on borrower choice of lender
- Seminary officers and employees receiving remuneration for service as a member or participant of an advisory board of a guarantor or lending institution involved in higher education loans, with the exception of receiving reasonable travel expense reimbursement.
*Definition of Gifts: A gift is any gratuity, favor, discount, entertainment, hospitality, loan or other item having greater than a small monetary value (approximately $10). A gift is not:
- a brochure, workshop or training using standard materials relating to a loan, default aversion or financial literacy;
- 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 institution’s officer, employee or agent;
- favorable terms and benefits on an education loan provided to a student employed by the institution if those terms and benefits are comparable to those provided to all students at the institution;
- 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.