Financial Aid Code of Conduct

The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid personnel. Accordingly, The Soma Institute {“the School”] has created the following code of conduct.

This policy applies to all employees who work in the Financial Aid Office and all other School employees, officers, and agents who have responsibilities with respect to education loans.

Conflict of Interest

No employee shall have a conflict of interest with respect to any education loan or other student financial aid for which the employee has responsibility. Such a conflict would exist when an employee’s financial interest or other opportunities for personal benefit might compromise, or reasonably appear to compromise, the independent judgment with which the employee performs their responsibilities at the School.

Ban on Revenue Sharing

The Soma Institute has not, and does not intend in the future, to enter into any revenue- sharing arrangements with any lender.

Gift Ban

Employees or their family members may not solicit and/or accept any gifts from lenders, guarantors, or servicers of education loans. A gift to a family member of an employee or to another individual based on that individual’s relationship with an employee shall be considered a gift to the employee if the gift is given with the knowledge and consent of the employee, and the employee has reason to believe the gift was given because of the employee’s position at the School. Token awards from professional associations that recognize professional milestones or extraordinary service to parents may be accepted. Also acceptable are scholarships for conference attendance or other professional development opportunities

The School will not accept any marketing gifts from lenders.

Prohibition on Contracting

Employees who work in the Financial Aid Office or who have responsibilities related to education loans may not accept from any lender or lender affiliate any fees, payments, or other financial benefit as compensation (including the opportunity to purchase stock) for any type of consulting arrangement or other contract to provide services to a lender relating to education loans.

Interaction with Borrowers

The School will not assign a first-time borrower’s private loan to a particular lender. The School will also not refuse to certify, or delay certification of, any federal loan based on the borrower’s choice of lender or guaranty agency

Prohibition on Offers of Funds for Private Loans

The School does not request or accept from any lender an offer of funds to be used for private education loans in exchange for promises to the lender with regards to the number of loans made, specific loan volume or preferred lender arrangement.

Ban on Staffing Assistance from Lenders

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

Advisory Board Compensation

No employee who serves on an advisory board, commission or group established by a lender, guarantor, or group of lenders or guarantors may receive anything of value from the lender, guarantor, or group of lenders or guarantors in return for that service.

Reimbursement of Expenses

Expenses incurred while attending professional association meetings, conferences, or in connection with service on an advisory board or commission must be paid by the School.

The Soma Institute participates in The U.S. Department of Education’s Direct Loan Program and does not use outside lenders or servicers to process Federal Financial Aid Loans.