Conflict of Interest & Code of Conduct

Conflict of Interest

  • A conflict of interest  exists when  an employee's  financial  interests  or other opportunities for personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the employee performs his/her  responsibilities at the College. 
  • No officer or employee shall be a party to or have substantial interest, financial or otherwise, whether directly or indirectly, in any contract (excluding their employment agreements) with the College. Nor shall any officer or employee, directly or indirectly, solicit any contracts or services between the College and any party or entity of which they, or members of their immediate families, are owners, partners, members, employees or have any substantial interest, financial or otherwise. 
  • No officer or employee shall place themselves in positions or situations, or otherwise incur an obligation of any nature, which shall preclude them from performing their duties and responsibilities in the best interests of the College.
  • It shall be the strict obligation of all officers and employees of the College to disclose to the Chancellor through their immediate supervisors, and the Chancellor to the Board of Trustees, any personal interests or involvement which may be the subject matter of a potential  conflict of interest under the terms of this policy.

Institutional Responsibilities 

Revenue Sharing

  • Oakland Community College will not enter into any relationship wherein they recommend a lender or loan product of a lender in exchange for a fee or other material benefit

Interaction with borrowers

  • Oakland Community College shall not assign a first time borrower's  loan to a particular lender or refuse or delay certification of any loan based on the borrower's  selection of a particular  lender.

Offers of funds for private loans

  • Oakland Community College shall not request or accept any offer of funds for private loans to a student in exchange for concessions or promises regarding providing the lender with a specific number  of Title IV  loans made, ensured, or guaranteed, a specified loan volume or a preferred lender agreement.

Ban on staffing assistance

  • Oakland Community College shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing except assistance related  to:
    • Professional develpoment training for financial aid administrators;
    • Providing educational materials including financial literacy, debt management materials to borrowers provided that such material disclosed the identification that a lender that assisted in preparing and providing such materials; or
    • Staffing services on a short term, non-recurring basis to assist with financial aid related functions during emergencies, including state declared or federally declared natural disasters or other localized disasters and emergencies identified by the Secretary of Education.

Individual Responsibilities

Gift Ban

No officer, employee, or agent in the financial aid office or with responsibilities with respect to educational loans shall solicit or accept any gift from a lender. Gift includes any item having a value more than a diminimus amount.

A gift to an individual based on that individual 's relationship with an officer, employee, or agent of Oakland Community College is considered a gift to the officer, employee, or agent if the gift was given with their knowledge and acquiescence or the person had a reason to believe it was given because of their position  at Oakland Community College.

Contracting Arrangements

No officer or employee or agent in the financial aid office or otherwise has responsibility with respect to education loans shall accept from any lender any financial benefit as compensation for any type of consulting arrangement or contract to provide services to a lender, or on behalf of a lender, related to education loans.

This does not prohibit any officer or employee not in the financial aid office but with responsibility with respect to education loans from providing paid or unpaid  services on such a board  that has a written conflict of interest  policy requiring recusal from participation in any decisions of the board regarding education loans at Oakland Community College.

Advisory Board Compensation

Any employee who is employed in the financial aid office or who otherwise has responsibilities with respect to education loans and who serves on an advisory board, commission, or group established by a lender shall be prohibited from receiving anything of value from the lender except that the employee may be reimbursed for reasonable expenses incurred in such service.