Institutional Policies & Regulatory Compliance

As a participant in federal loan programs, Bank Street College is required to develop, administer, and enforce a financial aid code of conduct applicable to the College’s officers, employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. Bank Street College of Education’s Code of Conduct Related to Student Loan Activities fulfills these requirements and applies to certain transactions and activities related to student lending and financial aid matters. Furthermore, Bank Street College of Education also adheres to the Student Lending, Accountability, Transparency and Enforcement (SLATE) Act under New York State law, which applies not only to the College’s officers, employees and trustees, but also to the College’s agents and contractors.

In addition, the financial aid professional at Bank Street College of Education is expected to always maintain exemplary standards of professional conduct in all aspects of carrying out his or her responsibilities, specifically including all dealings with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized, or regulated activity.

Revenue Sharing Prohibition: Bank Street College of Education employees are prohibited from receiving anything of value from any lending institution in exchange for any advantage sought by the lending institution.

Gift and Trip Prohibition: Bank Street College of Education employees are prohibited from taking anything of more than nominal value from any lending institution. This includes a prohibition on trips for financial aid officers and other college officials paid for by lenders.

Advisory Board Compensation Rules: Bank Street College of Education employees are prohibited from receiving anything of value for serving on the advisory board of any lending institution.

Staffing Assistance/Call-Center Prohibition: Bank Street College of Education employees are prohibited from accepting from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training, educational counseling materials  (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, nonrecurring basis during emergencies or disasters.

Consulting/Contracting Arrangement Prohibition: Bank Street College of Education employees are prohibited from accepting from any lender or affiliate of any lender any fee, payment, or other financial benefit 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.

Assigning of Lender to First-Time Borrower Prohibition: Bank Street College of Education Office of Financial Aid will not, for any first-time borrower, assign, through award packaging or other methods, the borrower’s loan to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.

Preferred Lender Lists: If Bank Street College of Education were to use a preferred lender list, the following standards shall be observed and maintained:

• A preferred lender list, if offered, will be based solely on the best interests of the students who may use the list without regard to financial interests of Bank Street College of Education.
• A preferred lender list, if offered, will have at least three or more unaffiliated lenders.
• A preferred lender list, if offered, will clearly and fully disclose the criteria and process used by Bank Street College of Education to select the lenders on the list. Students will be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.
• Lenders listed on a preferred lender list, if it is offered, must first disclose if the lender has an agreement to sell its loans to another lender. No lender will be listed if the lender bargains to be on the list with respect to a certain type of loan by providing benefits to Bank Street College of Education as to another type of loan.
• A preferred lender list, if offered, will provide comparative information on borrower benefits offered by all lenders, including, but not limited to, lenders’ interest rates and loan terms and conditions.
• Bank Street College of Education will endeavor to select lenders with the best borrower benefits, including, but not limited to, lenders’ interest rates and loan terms and conditions, for its preferred lender list, if offered.
• Bank Street College of Education will annually update its preferred lender list if it is offered.
• Bank Street College of Education will not be involved with any lender that  undertakes philanthropic activities in exchange for federal student loan applications, volume, or placement on a school’s preferred lender list

Bank Street College of Education under statutory language will not provide a commission, bonus, or other incentive payment based in any part, directly or indirectly, on success in securing enrollments or financial aid to any person or entity engaged in any student recruiting or admission activities or in making decisions regarding awarding Title IV funds.

In addition, Bank Street College of Education is prohibited from making adjustments to compensation for any employee engaged in any student recruiting or admission activities or in making decisions regarding awarding financial aid.

An annual adjustment in a calendar year is acceptable if the institution (Bank Street College of Education) can document that said adjustment is not based upon enrollments.

Multiple adjustments in a calendar year are considered to have been made based upon success in securing enrollments or awarding financial aid if those adjustments create compensation based in any part, directly or indirectly, on securing enrollment or awarding financial aid.

Bank Street College of Education, its contractors, and other entities may make acceptable compensation in the form of profit-sharing payments so long as such payments are not provided to any person who is engaged in student recruitment or admission activity or in making decisions regarding the award of Title IV funds.

Commission, bonus, or other incentive payment is defined as a sum of money or something of value, other than a fixed salary or wages, paid or given to a person or entity for services rendered.

Enrollment is defined as admission or matriculation of a student into an eligible institution.

Securing enrollment or the award of financial aid is defined as activities a person/entity engages in at any point in time through completion of an educational program for the purpose of admission or matriculation of students for any period of time or the award of financial aid to students.

Entity/person engaged in any student recruitment or admission activity or in making decisions about the award of financial aid means any institution or organization that undertakes the recruiting or the admitting of students or that makes decisions about and awards Title IV funds; and

Any person who undertakes recruiting or admitting of students or who makes decisions about and awards Title IV funds, and any higher level employee with responsibility for recruitment or admission of students, or making decisions about awarding Title IV funds.

Bank Street College of Education is prohibited under federal regulations from making any false, erroneous, or misleading statement directly or indirectly to a student, prospective student, member of the public, accrediting agency, state agency, or to the Department of Education.

Misleading statement includes any statement that has the likelihood or tendency to deceive or confuse. A statement is any communication made in writing, visually, orally, or through other means. This includes student testimonials given under duress or because such testimonial was required to participate in a program.

Federal regulations further provide that substantial misrepresentation is any misrepresentation on which the person to whom it was made could reasonably be expected to rely, or has reasonably relied, to that person’s detriment.

The regulations regarding misrepresentation describe misrepresentation with respect to:

• Nature of the education program
• Nature of financial charges
• Employability of graduates
• Relationship with the Department of Education. A Title IV eligible school may not describe its participation in a way that suggests approval or endorsement by the Department of Education of the quality of its educational programs.