Preferred Lender List for Private Loans

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1 Preferred Lender List for Private Loans St. Edward s University uses a Preferred Lender List to provide a starting point for families to begin researching private loans, to prevent families from dealing with risky products and unknown lenders, and to make it easier for families to make private loan decisions by having reliable information in one place. St. Edward s University Office of Student Financial Services has developed a Preferred Lender List, viewed through ELMSELECT ( meeting regulatory standards outlined in Section 34 CFR and of the Code of Federal Regulations as follows: +Annually compile, maintain, and make available to students attending St. Edward s, a list of the specific lenders for private education loans that the St. Edward s recommends, promotes, or endorses in accordance with such preferred lender arrangement; *Disclose why we participate in a preferred lender arrangement with each lender on the list, particularly with respect to terms and conditions or provisions favorable to the borrower; +Fully disclose that students attending St. Edward s do not have to borrow from a lender on the preferred lender list; +Disclose the method and criteria used to select lenders on the basis of the best interests of the borrowers including payment of origination or other fees on behalf of the borrower, highly competitive interest rates, high quality servicing for such loans, and additional benefits beyond the standard terms and conditions or provisions for such loans; +Include a minimum of two private educational loan lenders and indicate for each lender whether the lender is an affiliate of another lender on the list, in which case the list describes the details of this affiliation; +Prominently display a statement that the student may qualify for Federal Student Aid, including grants and loans and those conditions of such may be more favorable than the terms and conditions of private education loans. The opening statement on the St. Edward s University ELMSELECT page is as follows: + Alternative Educational Loans should only be considered once a borrower has explored the lower interest rate options available through the Federal Direct Loan Program and/or the Federal Direct Parent PLUS loan programs. Alternative Educational Loans provide educational funding options but generally have higher, variable interest rates as well as different repayments terms and options. Potential borrowers should carefully compare all loan terms and conditions.

2 +Borrowers should review their actual educational needs when determining the requested loan amount. Borrowers should only request loan funds to cover specific educational needs rather than the maximum allowed by the lender for the enrollment period. +St. Edward's University Office of Student Financial Services does not endorse any lender presented and has not ranked the lenders by any established measure. The list of lenders serves only as a general guide to assist student borrowers with educational funding options to fulfill their educational goals. The following established lenders have been placed on our lender list because they provide exemplary service and financing options that provide a wide range of benefits to their borrowers. A student borrower may select any lender and is not restricted to the lenders presented on the lender list provided. A borrower should not be directed to any specific lender by the University. +St. Edward's University does not receive any benefits in exchange for placing a lender on the lender list. For lender specific borrower's benefit; interest rates and repayment information please refer directly to the lender's website. +A student has the right to cancel their student loan, in part or in full. The request for cancellation must be submitted in writing to the St. Edward's University Office of Student Financial Services. +A lender may retain the borrower's promissory note while in school and through the repayment time period, while other lenders may sell the note to a secondary market for repayment. A borrower should contact the lender selected to determine their specific process.

3 Preferred Lender List Disclosures Schools who participate in a Preferred Lender Arrangement must disclose on the school s website, and in all other informational materials that discuss education loans, the following: +The information required for Preferred Lender Lists. (See section entitled Private Education Loans, and subtitled Preferred Lender List ); + Information required to be disclosed under section 128 (11) of the Truth in Lending Act. In accordance with the Truth in Lending Act, students borrowing private education loans must receive three required disclosures from their lender of choice at the following stages of the loan process: on or with the application; after loan approval; at consummation of the loan. The disclosures include for example, information on the amount financed, the finance charge expressed as an "annual percentage rate, the number, amount, and due dates or period of payments scheduled to repay the total of payments.( Disclosures will be provided by your lender of the student s choice). +A statement that the prospective borrower may qualify for FSA grants and loans, and that the terms and conditions of FSA loans may be more favorable than the terms and conditions of private education loans; +Upon a student s request for a private education loan, St. Edward s provides a link to the Self- Certification form for private education loans.

4 Preferred Lender List Code of conduct The Higher Education Opportunity Act of 2008 (HEOA) requires that institutions participating in the federal student loan programs develop, publish, and enforce a code of conduct with respect to student loans. St. Edward s University is committed to the highest standard of ethics and conduct, and therefore, Financial Aid staff are bound to the conflict of interest policies applicable to St. Edward s employees. Additionally, to comply with the HEOA, St. Edward s has adopted the following federally mandated Code of Conduct to address specific legislative concerns relating to educational loan programs. If any question arises as to whether an activity would be prohibited by either the University s conflict of interest policies or this Code of Conduct, employees should bring the matter to the attention of their supervisors before engaging in such activity. The University s conflict of interest policies, in some cases, bar conduct that is permitted by federal regulation, such that even if a gift, program, service, or other benefit is not proscribed by federal regulation, University policy may forbid it. For example, although HEOA permits the acceptance of certain gifts of minimal value, or reimbursement of certain expenses associated with service on boards, your supervisor may advise that such gifts or reimbursements are prohibited under University policy. HEOA, and as such St. Edward s University, requires the prohibition of the following activities: Participating in a revenue sharing arrangement with any lender. The HEOA defines revenuesharing arrangement to mean any arrangement between an institution and a lender under which the lender makes private education loans to students attending the institution (or to the families of those students), the institution recommends the lender or the loan products of the lender and, in exchange, the lender pays a fee or provides other material benefits, including revenue or profit sharing, to the institution or to its officers, employees, or agents; Receiving gifts from a lender, guaranty agency or loan servicer. No officer or employee of an institution s financial aid office (or an employee or agent who otherwise has responsibilities with respect to educational loans) may solicit or accept any gift from a lender, guarantor, or servicer of education loans. The regulations define a gift as any gratuity, favor, discount, entertainment, hospitality, loan, or other item having monetary value of more than a minimal amount. However, a gift does not include (1) standard materials, activities, or programs relating to a loan, default aversion, or financial literacy, such as a brochure, workshop or training; (2) food, training, or informational material provided as part of a training session designed to improve the service of a lender, guarantor, or servicer if the training contributes to the professional development of the institution s officer, employee or agent; (3) favorable terms and benefits on an education loan provided to a student employed by the institution, if those terms and benefits are comparable to those provided to all students at the institution; (4) entrance and exit counseling, provided that the institution s staff are in control of the counseling and the counseling does not promote the services of a specific lender; (5) philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans, or any contribution that is not made in exchange for advantage related to education loans, and; (6) State education grants, scholarships, or financial aid funds administered by or on behalf of a State;

5 Accepting from a lender, or an affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans; Directing borrowers to particular lenders or delaying loan certifications. For any first time borrower, an institution may not assign, through the award packaging or other methods, the borrower s loan to a particular lender. In addition, the institution may not refuse to certify, or delay the certification, of any loan based on the borrower s selection of a particular lender or guaranty agency; Requesting or accepting from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of private education loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement. An opportunity pool loan is defined as a private education loan made by a lender to a student attending the institution or the family member of such a student that involves a payment, directly or indirectly, by such institution of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family; Requesting or accepting from any lender any assistance with call center staffing or financial aid office staffing. However, a lender may provide professional development training, educational counseling materials (provided such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials), or staffing services on a short term, nonrecurring basis during emergencies or disasters; and Receiving advisory board compensation. An employee of an institution s financial aid office (or employee who otherwise has responsibilities with respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor, or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board.