Financial Aid

SCHOOL CODE OF CONDUCT FOR
FEDERAL STUDENT LOAN PROGRAM


May 2009

This code of conduct applies to all seminary employees, officers and agents - particularly to all who have responsibilities with respect to Federal Student Aid and student loans.

Concordia Theological Seminary (CTS) 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 compatibilities with our normal loan processing.
  • Choose lenders for the preferred lender list that have offered or provided inducements to this school.

 

CTS prohibits the following activities:

  • All revenue sharing between lenders and this school (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.