Student Loan Code of Conduct


The Ocean Corporation maintains the highest standards of administrative and academic integrity, and our employees conduct themselves in an ethical and professional manner in their interactions with students and families.  The Ocean Corporation has set forth this policy to codify and clarify our corporate ethics standard with regard to education (student) loan lenders, servicers, and or guarantors, and to provide assurances that questionable practices that have been criticized at other educational institutions are not occurring at The Ocean Corporation.

Code of Conduct Policy:

“Preferred” lender lists and endorsements of lenders:  The Ocean Corporation does not create, maintain, or distribute any listing of “preferred” or “recommended” education loan lenders/servicers, nor will Ocean Corporation staff endorse any particular education loan lender/servicer.

Promotion of Education Loans:  The Ocean Corporation does not engage in a “revenue sharing” arrangement with any student loan lender, servicer or guarantor, nor enter into any arrangement designed to promote the products, services, and/or public image of any student loan lender, servicer, or guarantor.  This section does not prohibit the school from distributing informational materials in compliance with federal regulation 34 C.F.R. 682.200(b)(5)(ii).

Non-Discrimination in Loan Certification: The Financial Aid Office will certify any private loan application in a timely manner for an eligible student through any lender, servicer or guarantor.  Financial Aid Office staff neither favor nor discriminate against any particular student loan lender, servicer, or provider in giving counsel to student and parent borrowers.  However, nothing in this policy shall be construed to prevent properly trained Financial Aid Office staff from providing students and parents with good counsel and honest answers about loan costs, interest rates, processing times, methods of payment, and past customer service experience to assist the borrower in making an educated lender choice. 

Prohibition Against Gifts:  Neither the Ocean Corporation nor any of its employees will accept any gift, gratuity, favor, discount, entertainment, hospitality, benefit, or any other item of more than a nominal value from any student loan lender, servicer or guarantor, except as specifically permitted in federal regulation 34 C.F.R. 682.200(b)(5)(ii).  Gifts to family members of Ocean Corporation employees are considered as a gift to the employee if the gift was given in relation to the position of the Ocean Corporation employee.  Nothing in this section shall be construed as prohibiting Ocean Corporation employees from conducting normal banking business with a student loan lender; or receiving discounts, premiums, or gifts that are available to the general public based upon that normal banking business. 

Contracting Arrangements/Advisory Groups:  Financial aid employees or any other Ocean Corporation staff member that may have any responsibility with respect to educational loans may not accept from any student loan lender, servicer or guarantor any type of fee, payment, or other financial benefit as compensation for consulting or other services provided on behalf of the lender relating to educational loans; nor shall any employee except payment for services or reimbursement of expenses related to education lending advisory boards, focus groups, facility tours or similar activities from any student loan lender, servicer, or guarantor.

Staffing Assistance:  The Ocean Corporation does not utilize student loan lender, servicer, or guarantor staff to work in our offices, nor will we allow them to perform the work of school personnel in other locations.  Further, we do not permit any non-employee to identify him/herself as an Ocean Corporation employee.

Revised June 8, 2010
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