Policies

Higher Education Act Standard for School/Lender Relations (P. L. 110-315)

Prohibition Against Remuneration to Western Illinois University

Western will not solicit, accept or agree to accept anything of value from any Lending Institution, Guarantee Agency or Servicer in exchange for any advantage or consideration provided by the Lending Institution related to its student loan activity. This prohibition covers, but is not limited to:

Prohibition Against Remuneration to Western Illinois Employees

Western will require and enforce that no officer, director, employee or agent of the University will accept anything having a monetary value amount more than a token (nominal) on his or her own behalf or on behalf of another during any 12 month period from, or on behalf of any Lending Institution, Guarantee Agency or Servicer.

This prohibition will include, but not be limited to a ban on any payment or reimbursement from any Lending Institution, Guarantee Agency or Servicer to University employees for lodging, meals, or travel to conferences or training seminars.

This does not preclude any officer, trustee, director, employee or agent of the University from receiving compensation for conducting non-University business with a Lending Institution, Guarantee Agency or Servicer or from accepting compensation that is offered to the general public.

This prohibition does not prevent the University from holding membership in any non-profit professional association.

Prohibition of Gifts

No person at Western involved in any aspect of student loans shall solicit or accept any gift from a Lender, Guarantor, or Servicer of student loans. This includes but is not limited to financial aid administrators, supervisors of financial aid administrators, Business Office personnel who deal with loans, anyone who otherwise has responsibility or authority over the financial aid operation and anyone who has anything to do with the decision making process regarding student loans to include officers and trustees for any of the above. Further, this would include gifts to family members if:

Gifts are defined as but not limited to:

The following items are not considered as gifts:

Entrance and exit counseling services provided to borrowers in meeting the institution's responsibilities for entrance and exit counseling as required as long as:

Ban on Gifts to Family Members

Gifts to family members of any officer, trustee, director or university employee will be considered a gift to said officer, trustee, director or university employee if:

the gift is given with the knowledge and acquiescence of the officer, trustee, director or university employee and the officer, trustee, director or university employee has reason to believe the gift was given because of the official position of said officer, trustee, director or university employee.

Limits of University Employees Participating on Lender Advisory Boards

Western will require and enforce that no officer, trustee, director or employee of the University from receiving any remuneration for serving as a member or participant of an advisory board of any Lending Institution, Guarantee Agency or Servicer or in receiving any reimbursement of expenses from said participation.

This does not preclude any officer, trustee, director or employee from participating on any lender advisory board that is unrelated to student loans.

This does not preclude any Western employee not involved in the affairs of the University's Financial Aid Office from serving on the Board of Directors of a publicly traded or privately held company.

Contracting Arrangements Prohibited

Any officer, trustee, director or employee is prohibited from accepting any payments of any kind from a lender in exchange for any type of consulting services related to educational loans. Further:

Revenue Sharing Agreements Prohibited

Western will not enter into any revenue sharing agreement in which:

a lender provides or issues a loan that is made, insured or guaranteed under this title to students attending the institution or to the families of such students; and the institution recommends the lender and in exchange the lender pays a fee or provides other material benefits.

Prohibition on Offers of Funds for Private Loans

Western will not request or accept any agreement or offer of funds for private loans in exchange for concessions or promises of:

Ban on Staffing Assistance

Western will not request or accept from any lender any assistance with call center staffing or financial aid office staffing.

This does not include:

Interaction With Borrowers

Western will provide the reasons certain lenders were selected, if a preferred lender list is used.

First-time borrowers will be asked to select a lender before a loan is processed.

Western will not refuse to certify, or delay certification of any loan based on the borrower's selection of a particular lender or guaranty agency.