Keiser University

Institutional Code of Conduct for Educational Loans

The Higher Education Act ( HEA ) requires that all schools enforce a code of conduct governing educational loan activities. Loan activities at Keiser University are those that are associated with any loan made under the Federal Direct Loan Program or any private educational loan. Any loan not made or guaranteed under Title IV of the HEA and is issued to a borrower for an educational expense is referred to as a private education loan.

This Institutional Code of Conduct applies to:

  • All officers
  • All employees
  • All trustees
  • Contract employees
  • Any agent – board members or other organizations that are directly or indirectly associated with anyone employed at Keiser University

I. Revenue Sharing Prohibited

The Institution’s officers, employees or any agents are prohibited from accepting any solicitation or fee of any sort or participating in any profit sharing in any form, for the exchange of recommending a student to a specific private loan lender or any of that lender’s products.

Impermissible Activities

Officers, employees and any agent of the institution that is employed by the financial aid office, or who has contact with any private education loans or responsibilities with respect to federal loans, may not accept or solicit gifts from any private student loan lender or servicer. See exceptions under “Permissible Activities”.

Definition of Gift – A favor, any gratuity, entertainment ( this includes sporting events, alcoholic beverages, shows, travel or meals ) or financial benefit.

If you are offered a gift by a lender or servicer, you must decline the offer of a gift immediately. Your family members and close friends must not accept gifts from a lender or servicer if the gift was offered because of your position with the institution.

A “gift” does not include standard materials, activities or programs on issues related to a loan product, default prevention, debt management or financial literacy, such as a brochure, a workshop or training, provided that students are informed of the name of any education lender or servicer that assisted in preparing or providing such materials, activities or programs.  Printed materials must contain the name of the education lender or servicer that provided such materials and should not contain any institution logos or trademarks.

The institution may also use online entrance and exit counseling tools provided by lenders or by servicers of loans, as long as:

  • The Institution is in control of the counseling session; and
  • The counseling does not promote the specific products or services of any specific lender.

Permissible Activities

Officers, employees and any agent of the institution may accept informational material provided as part of training by a lender or servicer. As long as the materials are a form of marketing or advertising such as pens, pencils, notepads, sticky-notes, rulers, calculators, small tote bags, or any daily usable office supply items.

When a lender or servicer provides training or professional development you may accept food, or any informational material provided as part of training by a lender or servicer provided the training contributes to your professional development.

If you are invited by a lender or servicer to a meal or form of entertainment you must pay for your own expenses. If appropriate under the institutions expense reimbursement policy, you may request reimbursement from the institution.

Packaging of Private Loans

A student may be packaged for a private loan under the following conditions:

  • The student refuses to apply for a Title IV loan, including a Parent PLUS loan
  • The Free Application for Federal Student Aid (FAFSA) has not been filled out
  • The student has exhausted the limits of his or her eligibility for Title IV loans (Federal Stafford, and as applicable, Parent PLUS)
  • The student is ineligible for additional funding

II. Choice of Lender

Impermissible Activities

The institution has a Preferred Lender List ( PLL ) that the financial aid office will not use to:

  • Obstruct or deny a borrower’s choice of lender
  • Delay certifying a loan that is not on the PLL
  • Designate a first time borrower’s loan to a particular lender
  • Require that the student use a lender on the PLL

Permissible Activities

Officers, employees and any agent of the institution that is employed in the financial aid office can make known of the PLL that is viewable on the institutions website. Student can apply with any lender on the list or any other lender of choice.

III. Consulting and Contractual Arrangements

Officers, employees and any agent of the institution who is employed in the financial aid office or has direct responsibilities or involvement with educational loans will not accept from any lender or its affiliate any payment, fee, or other financial benefit as a compensation for any type of consulting arrangement or other contract to provide service to or on behalf of the lender. A prohibited financial benefit includes the opportunity to purchase stock on less than free market terms.

IV. Loan Counseling

The Institution may accept assistance from the lender in conducting the initial entrance or exit loan counseling for students provided:

  • Financial Aid staff is in control of the counseling
  • The lender does not promote a specific product or service. However, the lender may promote benefits under other available federal and state programs.

V. Opportunity Pools

An opportunity pool means an educational loan made by a private lender to a borrower that the Institution guarantees in any manner or that involves the Institution directly or indirectly paying points, premiums, additional interest, or other financial support to the lender for the purpose of that lender extending credit to the borrower.

Impermissible Activities

The Institution will not promise to deliver a specified number of loans or loan volume by soliciting or accepting from any lender an opportunity pool to be used for private educational loans.

Permissible Activities

The Institution may solicit any lender for an opportunity pool to be used for private education loans, if it is not provided in exchange for a promise that the Institution will deliver to the lender a specified number of loans or volume.

VI. Preferred Lender Arrangements

An arrangement or agreement between the institution and an organization affiliated with the institution and a lender that provides an educational loan to students in which the institution promotes or endorses the lender’s education loan product.

Any private lender with whom the institution or any of its affiliated organizations displays information and documentation related to the lender loans is considered a lender arrangement.

Preferred Lender List ( PLL ) - Private lenders that the institution recommends are considered a preferred lender list.

VII. Preferred Lender List Alternatives

The Institution may provide an overall list of lenders that have made loans to our students or parents in the past so long as those lenders have indicated that they would continue to make loans to our students or parents in the future. None of the information provided will discuss the percentage of loans made to our students, and any additional information regarding the lender is prohibited. The Institution will make a clear statement that the student can choose to use any private lender of their choice and that we do not endorse the lender.

VIII. Publications

Impermissible Activities

The institution will not allow a private lender to use the name of the institution, logo, emblem or symbol in marketing the private educational loan to our students or parents implying that the institution endorses the lender’s private educational loans.

Permissible Activities

The institution can accept complimentary default prevention, debt management or financial literacy materials, such as a brochure publication from a private lender or servicer. The materials are to disclose the identity of the entity that assisted in preparing or providing the materials. Entrance and exit loan counseling materials, on-line resources and counseling materials may also be allowed at the institution.

IX. Assistance in Staffing

Impermissible Activities

The institution is not permitted to allow a private lender to staff any financial aid offices.

X. Technology

Impermissible Activities

The Institution is prohibited from accepting any computer hardware or computer software that is not related to financial aid or educational loan processing.

Permissible Activities

The Institution is allowed to accept free of charge from the lender or financial aid servicer related software, loan processing data transmission services, and a toll-free telephone number to obtain information on educational loans. Violations of the institutions policies, including the failure to avoid a prohibited activity or disclose a conflict of interest in a timely manner, will be dealt with in accordance with applicable policies and procedures, which may include disciplinary actions up to and including termination from the institution.

XI. Seeking Assistance

If you have a question regarding any statement contained in this Institutional Code of Conduct, or you are aware of any breach, please contact the Associate Vice Chancellor of Student Financial Services, Fred Pfeffer at ( 954 ) 776 – 4476 ext. 1172.

15

The Design program at Keiser University was filled with real world learning and hands on instruction… Based on the portfolio I created while a student at Keiser University, I landed a job in Graphic Design for a major online retailer immediately after graduation.

Ty Fitzgerald, Graphic Arts and Design Graduate

The year and a half I spent in the program better prepared me for attaining a job in the field…As a hands-on learner, the project-centered teaching was perfect for me.

Jackson Tejada, Graphic Arts and Design Graduate

Keiser University has given me the opportunity to embrace a career change… It has opened the door for a timely graduation and quick return to the work force…

Dale Caverly, Occupational Therapy Assistant Graduate

Without the education I received at Keiser University, I would not be where I am today!

Meisha Ebanks, R.N., Nursing Graduate

I not only received an excellent education but also encouragement and training that built my self-confidence every day.

Nidia Barrios, Medical Assisting Graduate

I realize the amount of knowledge I gained and feel that the educational experiences have developed me in to a person who can move higher up the career ladder.

Carlos Ramirez Flores, BA in Accounting Graduate

Keiser University’s MBA program has renewed my mind, changed the way I think, and given me a new sense of purpose.  The professors transformed my attitude and behavior, gave me the self-confidence I was lacking, and restored my energy.

Connie Sue Centrella, MBA Graduate

It has been great attending and graduating from Keiser University.  Because of the small class sizes, I was able to build good relationships with classmates and professors.  The PA professors care very much about the progress and success of the students and have been great advisors every step of the way through the program.

Annelise Merriner, PA-C, MS in Physician Assistant Graduate

Attending Keiser University and getting my degree was the best decision I have ever made.  The small class sizes and personalized attention helped me get my degree quickly.  The hands-on experience and the education landed me a job at a neighboring law firm.

Dedrick Saxon, Criminal Justice Graduate

I chose Keiser because it had everything—small classes, caring professors, hands-on learning, and counselors that are really there for you.  I feel like I’m part of a family here, not just a number.

Natalie Dou, Histotechnology Graduate

After being denied for several promotions at my current employer, I decided that I needed to further my education.  Since graduating from Keiser with my bachelor’s degree in Business Administration, I have been promoted and I am able to obtain positions that weren’t available to me before.

Laurie Williams, BA in Business Administration Graduate

Keiser helped change my life by getting my education at the right school! I have been going to another school before, dropped out because I felt that I was not getting enough information that I need. When I found out about Keiser, I was pleased because the instructors were great.

Nadege Dor, Medical Assisting Graduate

My decision to attend Keiser University has been one of the best decisions I’ve made. I chose to enroll in the Information Technology program… The one-class-a-month pace helped incredibly with my self-discipline.

Marla Hadley, Information Technology Graduate

The BA for Business Administration at Keiser has to be one of the best in the nation. Keiser takes the basics that are taught at the Associates level and uses them to strengthen your skills and knowledge.

Vivian R. Howard, BA in Business Administration Graduate

I found that Keiser University’s Nuclear Medicine program of advanced studies and small class size was a perfect fit. I never came across a faculty member who wasn’t truly interested.

Gustavo Gonzalez, Nuclear Medicine Technology Graduate