Code of Conduct

Central Methodist University (the "University") hereby adopts the following Code of Conduct to ensure that no improprieties or conflicts, whether actual, potential, or perceived, arise in connection with student loans or preferred lender designations and to reaffirm its commitment to serving the needs of its students and their parents.

Prohibition of Certain Remuneration to University Employees

1. No officer, trustee, director, employee, or agent of the University shall accept anything of more than nominal value on his or her own behalf or on behalf of another from or on behalf of a Lending Institution, except that this provision shall not be construed to prohibit any officer, trustee, director, employee, or agent of the University from conducting (i) non-University business with any Lending Institution; or (ii) University business unrelated to education loans. As used in the preceding sentence and throughout the Code of Conduct, a Lending Institution is defined as:

(a )Any entity that itself or through an affiliate engages in the business of making loans to students, parents or others for purposes of financing higher education expenses or that securitizes such loans; or

(b) Any entity, or association of entities, that guarantees education loans


(c) Any industry, trade or professional association that, to the best of the University's knowledge after reasonable inquiry, receives money from any entity described above in subsections (a) and (b).

2. Nothing in this provision or throughout the Code of Conduct shall prevent the University from holding membership in any nonprofit professional association.

3. The prohibition set forth in Paragraph 1 shall include, but not be limited to, a ban on any payment or reimbursement by a Lending Institution to a University employee for lodging, meals, or travel to conferences or training seminars unless such payment or reimbursement is related solely to non-University business or University business unrelated to education loans.

Limitations on University Employees Participating on Lender Advisory Boards

4. The University shall prohibit any of its officers, trustees, directors, employees, or agents from receiving any remuneration for serving as a member of or participant in an advisory board of a Lending Institution, or receiving any reimbursement of expenses for so serving, provided, however, that participation on advisory boards that are unrelated in any way to higher education loans shall not be prohibited by the Code of

Prohibition of Certain Remuneration to the University

5. The University shall not accept on its own behalf anything of value from any Lending Institution in exchange for any advantage or consideration provided to the Lending Institution related to its education loan activity. This prohibition shall include, but not be limited to, (i) "revenue sharing" by a Lending Institution with the University, (ii) the University's receipt from any Lending Institution of any computer hardware for which the University pays below-market prices and (iii) printing costs or services paid directly on behalf of the University. Notwithstanding anything else in this paragraph, the University may accept assistance as contemplated in 34 CFR 682.200(b)(definition of "Lender")(S)(i).

Preferred Lender Lists

6. In the event that the University promulgates a list of preferred or recommended lenders or similar ranking or designation ("Preferred Lender List"), then

(a) Every brochure, web page or other document that sets forth a Preferred Lender List must clearly disclose the process by which the University selected lenders for said Preferred Lender List, including but not limited to the criteria used in compiling said list and the relative importance of those criteria; and

(b) Every brochure, web page or other document that sets forth a Preferred Lender List or identifies any lender as being on such Preferred lender List shall state in the same font and same manner as the predominant text of the document that students and their parents have the right and ability to select the education loan provider of their choice, are not required to use any of the lenders on the Preferred Lender List, and will suffer no penalty for choosing a lender that is not on the Preferred Lender List.

(c) The University's decision to include a Lending Institution on any such list and the University's decision as to where on the list the Lending Institution's name appears shall be determined without regard to the pecuniary interests of the University;

(d) The composition of any Preferred Lender List shall be reviewed no less than annually;

(e) Any Preferred Lender List shall be composed of at least three Lending Institutions;

(f) No Lending Institution shall be placed on any Preferred Lender List unless such lender provides assurance to the University and to student and parent borrowers who receive loans from such Lending Institution that the advertised benefits upon repayment will continue to inure to the benefit of student and parent borrowers regardless of whether the Lending Institution's loan are sold;

(g) No Lending Institution that, to the best of the University's knowledge after reasonable inquiry, has an agreement to sell its loans to another unaffiliated Lending Institution shall be included on any Preferred Lender List unless such agreement is disclosed therein in the same font and same manner as the predominant text on the document in which the Preferred Lender List appears;

(h) The University shall not place any Lending Institution on any Preferred Lender List or in favored placement on any Preferred Lender List for a particular type of loan, in exchange for benefits provided to the University or to the University's students in connection with a different type of loan unless such benefits are fully disclosed on the Preferred Lender List.

Prohibition of Lending Institutions' Staffing of University Financial Aid Offices

7. The University shall ensure that no employee or other agent of a Lending Institution is ever identified to students or prospective students of the University or their parents as an employee or agent of the University. No employee or other agent of a Lending Institution may staff the University financial aid offices at any time, except that a Lending Institution may assist the University in informing students about educational loans and other aspects of financial aid, provided that any employees or other agents relationship to the Lending Institution is disclosed.

Proper Execution of Master Promissory Notes

8. The University shall not link or otherwise direct potential borrowers to any electronic Master Promissory Notes or other loan agreements that do not allow students to enter the lender code or name for any lender offering the relevant loan.

School as Lender

9. If the University participates in the "School as Lender" program under 20 U.S.C. § 1085(d)(l)(E), the University shall be guided by this Code of Conduct, as applicable, in the administration of School as Lender loans.

Prohibition of Opportunity Loans

10. As used herein, "override pools," "opportunity funds," and "opportunity loans" refer to any agreement, understanding or practice in which a lender applies more lenient loan underwriting criteria than it otherwise would to a certain class of loan applicants if the University meets certain milestones or metrics with respect to other loans with that lender, such as the number of loans initiated or in force, or the dollar amount of such loans, or where the lender agrees with the University to lend money to students outside the Federal Family Education Loan Program (FFELP), at the University's direction, in exchange for the University's withdrawing from the federal direct loan program and/or marketing the lender's separate FFELP loans to students.

11. The University shall not arrange with a Lending Institution to participate in any override pools, opportunity funds, or opportunity loans, as defined above, if the participation in such program(s) prejudices any other borrower.

12. The University will not steer a first-time borrower to any particular lender through award packaging or any other method, such as advertisement, promotion, or publication on the University's website, through email, or other method.

13. The University will not delay or refuse certification of any loan based on the borrower's lender selection.

14. The University prohibits conflicts of interest as they relate to the awarding and disbursing of Title IV student loans. No person related to a student may award or disburse student loans to that student.