SCHOOL CODE OF CONDUCT FOR
FEDERAL STUDENT LOAN PROGRAM
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.