Student Loan Code of Conduct

The RAND School of Public Policy (“the School”) is committed to maintaining the highest standards of integrity and transparency in all financial aid and education loan practices. This Loan Code of Conduct establishes clear guidelines to ensure that all institutional employees act in the best interests of students and borrowers, free from conflicts of interest or undue influence from lenders, guaranty agencies, or loan servicers.

  1. Revenue-Sharing Arrangements

    The School shall not enter into any revenue-sharing arrangement with any lender or loan servicer.

  2. Gifts from Lenders, Guaranty Agencies, or Loan Servicers

    No employee of the School’s financial aid office, nor any other institutional employee with responsibilities related to education loans, shall solicit or accept any gift from a lender, guaranty agency, or loan servicer.

    • “Gift” means anything of value for which equal payment is not provided. Examples of Gifts include cash, gift cards, tangible goods, meals, tickets to events, travel, and discounts that are not available to all RAND Associates or to the public.
  3. Compensation for Consulting or Contractual Arrangements

    No employee of the financial aid office or any other institutional officer or employee with education loan responsibilities shall accept any fee, payment, or other financial benefit—including the opportunity to purchase stock—from a lender or servicer as compensation for consulting or providing services related to education loans.

  4. Steering Borrowers to Particular Lenders

    The School shall not assign, recommend, or steer first-time borrowers to any particular lender through loan packaging, website listings, publications, or other methods. All borrowers shall be free to select the lender of their choice for private or Title IV loans, and the School shall provide unbiased information to assist in that selection.

  5. Certification of Loans

    The School shall not refuse to certify, or unnecessarily delay certification of, any loan based on a borrower’s choice of lender or guaranty agency. Loan certifications shall be processed promptly and in accordance with federal and state regulations.

  6. Offers of Funds for Private Education Loans

    The School shall not request or accept offers of funds from any lender for private education loans—including opportunity pool loans—in exchange for concessions or promises to provide a specified number or volume of loans, or to establish preferred lender arrangements. All private loan arrangements must be free from any quid pro quo or preferential treatment.

  7. Staffing Assistance from Lenders

    The School shall not accept call center or financial aid office staffing assistance from any lender, guaranty agency, or loan servicer. Limited exceptions may apply only as permitted by statute and regulation.

  8. Advisory Board Compensation

    No employee of the financial aid office or other institutional employee with education loan responsibilities shall receive compensation for serving on any advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors. Employees may be reimbursed only for reasonable expenses incurred in connection with such service.