TITLE IV CODE OF CONDUCT POLICY
The department of Education requires Universities, Colleges and Trade schools participating in any of the Title IV loan programs to develop, publish, and enforce a code of conduct. This code of conduct applies to all officers, employees, and agents of Houston International College Cardiotech Ultrasound School (HICCUS).
All Officers, employees, and agents of HICCUS who have responsibilities with respect to student educational loans must comply with this code of conduct.
Ban on revenue-sharing arrangement with any lender:
Neither HICCUS as an institution nor any individual officer, employee or agent shall enter into any revenue sharing arrangements with any lender.
Ban on receiving gifts from a lender, guaranty agency or loan servicer:
No officer, employee, or agent, 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 minimum amount.
Ban on contracting arrangements:
No officer, employee, or agent of HICCUS shall 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.
Prohibition against steering borrowers to particular lenders or delaying loan certifications:
HICCUS shall not assign through award packaging or other methods any first—time 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.
Prohibition on offers of funds for private loans:
HICCUS shall not request or accept from any lender an offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of Title IV loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement. An “opportunity pool loan” is defined as a private education loan made by a lender to a student that involves a payment by the institution to the lender for extending credit to the student.
Ban on staffing assistance:
HICCUS shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing.
Ban on advisory board compensation:
No one employed in the financial aid office or that has any responsibilities with respect to education loans or other student financial aid shall derive any material benefit from serving on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors. However, such individuals may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.