Financial Aid Code of Conduct
If a student or team member has a concern with
Academy Di Capelli’s compliance The Higher Education Opportunity Act (HEOA)
requires educational institutions to develop and comply with a code of conduct
that prohibits conflicts of interest for financial aid personnel [HEOA Section
487 (a) (25)]. The purpose of this Code of Conduct is to ensure that our
students’ best interests are always at the forefront of all decisions we make.
Any officer, employee, or agent who has responsibilities with respect to
student educational loans at Academy Di Capelli must comply with this Code of
with Applicable Laws and Regulations
Academy Di Capelli has a policy to observe all laws, rules, and regulations of
government regulatory agencies and authorities that oversee the school. This
specifically includes requirements under the Higher Education Act, regulations
of the United States Department of Education, the policies of the school’s
accrediting agency, as well as other state and federal laws. If federal, state
or local law exists that is either contradictory or stricter then this policy,
employees must apply the law.
or Officer Compensation Prohibition
No employee or officer of the school shall accept or solicit any gift from a
lender, guarantor, or servicer of education loans other than of a nominal
value. “Nominal value” means a total retail value of not more than ten dollars
($10.00) as calculated over a 12- month period. For purposes of this
prohibition, the term “gift” means any gratuity, favor, discount,
entertainment, hospitality, loan, or other item.
Lender Advisory Board Restrictions
Any school employee or officer shall not accept any remuneration or reimbursement of expenses for serving as a member of
or otherwise participating on a student loan lender’s advisory board,
commission, committee, or group established by a lender, guarantor, or group of
lenders or guarantors, and shall be prohibited from receiving anything of value
from the lender, guarantor, or group of lenders or guarantors, except that the
employee or officer may be reimbursed for reasonable expenses incurred in
serving on such advisory board, commission, committee, or group.
Financial Relationship Prohibition
An officer or employee of the school who is employed in the financial aid office, or who otherwise has responsibilities with respect to educational loans or an
agent who has responsibilities with respect to education loans, shall not
accept from any lender or affiliate of any lender any fee, payment, or other
financial benefit (including the opportunity to buy 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. The school
prohibits employees, representatives, or agents of a lender for representing
themselves as employees of the school to students or parents.
Prompt Certification of Loans from Any Lender
The School shall not: a) for any first-time
borrower, assign, through award packaging or other methods, the borrower’s loan
to a particular lender; or b) refuse to certify, or delay certification of, any
loan based on the borrower’s selection of a particular lender or guaranty
school shall not engage in revenue sharing with any student loan lender.
“Revenue sharing” means any arrangement between the school and a student loan
lender under which the lender provides or issues loans to students attending
the school or to the families of such students; and the school recommends the
lender or the loan products of the lender and in exchange, the lender pays a
fee or provides other material benefits, including revenue or profit sharing,
to the school or its agent.
school shall not request or accept from any lender any offer or funds or be
used for private education loans, including funds for an opportunity pool loan,
to students in exchange for the institution providing concessions or promises
regarding providing the lender with: a) a specified number of private
educational loans (non-Title IV loans) or loans made, insured, or guaranteed
under Title IV; b) a specified loan volume of such loans; or c) a preferred
lender arrangement for such loans. An “opportunity” loan means a student loan
provided to borrowers with poor or no credit history, or who otherwise would
not meet the student loan lender’s eligibility criteria.
Staffing Assistance from Lenders
school shall not request or accept from any lender any assistance with call
center or financial aid office staffing, including in-person school required
initial or exit counseling, except as permitted by applicable federal student
Conflict of Interest
school strictly prohibits conflicts of interest between the school and lenders,
servicers, or guaranty agencies.
school shall require all of its employees with direct responsibilities relating
to student loans to obtain training concerning Student Loans.
of Conduct, applicable federal and state student loan laws and regulations, and
related school policies and procedures within 30 days of the date the school
adopts this Code or, for new employees, within 30 days of the date of hire. The
school shall review its Code of Conduct with all employees who have a direct
responsibility relating to student loans by July 1st of each year or within 30
days of new requirements going into effect to ensure these employees maintain
current knowledge of the Code and applicable regulations. In addition, each
year Academy Di Capelli will review its policy and procedure as part of its
compliance plan and in order to ensure that the school is in full compliance
with all regulations governing the school.
you have any questions with any of the requirements in the Code of Conduct you
can contact Tracy Swinarski, Financial Aid Director, at our main campus at
203-294-9496 ext 202.
(Revised June 2, 2018)