Franklin College Financial Aid Employee Code of Conduct

Policy Statement

Franklin College, as a participant in the Federal Direct Loan program, is required to have a code of conduct applicable to the institution’s officers, employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) of 2008. Franklin College has adopted conflicts of interest and commitment policies but the Code of Conduct Related to Student Loan Activities is an additional requirement specific to certain transactions and activities related to financial aid matters. In addition, the law includes requirements related to publication of the code and annual disclosures.

Policy Rationale

The HEOA program participation agreement which must be executed by all institutions participating in Title IV financial aid programs including student loan programs, requires a code of conduct with which the institution’s officers, employees, and agents shall comply. Such code must prohibit a conflict of interest with the responsibilities of an officer, employee, or agent of an institution with respect to such loans, and include the provisions set forth in the HEOA related to conflicts. The law further specifies that the code shall be displayed prominently on the institution’s website and that all institutional officers, employees and agents with responsibilities related to such loans be annually informed of the provisions of the code of conduct.

Sanctions

Violations of college policies, including the failure to avoid a prohibited activity or disclose a conflict of interest in timely manner, will be dealt with in accordance with applicable college policies and procedures, which may include disciplinary actions up to and including termination from Franklin College.

Franklin College Financial Aid Student Code of Conduct

A federal or state drug conviction may disqualify a student for Federal Student Aid (Title IV) funds.  The student self-certifies on the FAFSA (Free Application for Federal Student Aid) as to whether or not they are eligible.  If the institution has evidence of conflicting information, they may dispute the student’s eligibility.

For further details regarding financial aid penalties associated with violating federal or state drug laws please refer to the following resource:

• Federal Student Aid Handbook

For further details regarding Franklin College’s policies, procedures and penalties associated with federal, state or local violations please refer to the following resource:

• Franklin College Student Life Policies and Procedures

Financial Aid Complaints Procedures

The Commission for Higher Education (CHE) is responsible for responding to formal complaints against public, independent non-profit and proprietary institutions of higher education in Indiana.  For additional information regarding the Commission’s formal complaint process, please feel free to contact the Commission via complaints@che.in.gov.

The Higher Learning Commission (HLC) is Franklin College’s regional accreditation entity.  The HLC’s complaint process is designed to identify substantive problems with an institution’s ability to meet the Criteria for Accreditation.  For additional information regarding the HLC’s policy on complaints or to file a complaint, please click here.

Truth in Lending Requirements

As of February 2010 all private loan lenders are required to provide student borrowers three disclosure statements and a new Self Certification Form prior to the school being able to certify the loan. The Self Certification Form is to be completed by the student and returned to the lender. A waiting period of 3 business days is required between the time the borrower received the final loan disclosure and the time the loan is disbursed.

Private student loans are variable and fixed interest programs with interest that accrues while the student is in school.  Students (or co-borrowers) must have a good credit history to obtain private student loans.  Private student loans must be certified for the amount requested, up to the Cost of Attendance minus other financial aid the student is receiving at the time of certification.
Disclosures the student will receive:

1. Application Disclosure
2. Loan Approval Disclosure
3. Final Disclosure (prior to disbursement)

It is important to be timely in providing all information to your lender and acknowledging the above disclosures. Failure to do so will delay disbursement.