The Higher Education Opportunity Act, Public Law 110-315 — August 14, 2008, requires institutions that participate in the Title IV loan program to develop, publish, administer and enforce a code of conduct with which the institution’s officers, employees and agents shall comply.

The Code of Conduct for the Lake Erie College of Osteopathic Medicine (Erie, Bradenton and Seton Hill), the LECOM School of Pharmacy (Erie and Bradenton) and LECOM School of Dental Medicine (Bradenton) is as follows:

The Lake Erie College of Osteopathic Medicine, School of Pharmacy and School of Dental Medicine are committed to providing students and their families with the best information and processing alternatives available regarding student borrowing. In support of this and in an effort to rule out any perceived or actual conflict of interest between LECOM officers, employees or agents and education loan lenders, LECOM has adopted the following student lending code of conduct for the Erie, Bradenton and Seton Hill campuses:

• LECOM does not participate in any revenue-sharing arrangements with any lender.
• LECOM does not permit any officer, employee or agent of the school who is employed in the financial aid office or is otherwise involved in the administration of education loans to accept any gifts of greater than a nominal value from any lender, guarantor or servicer.
• LECOM does not permit any officer, employee or agent of the school who is employed in the financial aid office or is otherwise involved in the administration of education loans to accept any fee, payment or other financial benefit (including a stock purchase option) from a lender or affiliate of a lender as compensation for any type of consulting arrangement or contract to provide services to a lender or on behalf of a lender relating to education loans.
• LECOM does not permit any officer, employee or agent of the school who is employed in the financial aid office or is otherwise involved in the administration of education loans to accept any thing of value from a lender, guarantor, or group of lenders and/or guarantors in exchange for service on an advisory board, commission or other group established by such a lender, guarantor group of lenders and/or guarantors. LECOM does allow for the reasonable reimbursement of expenses associated with articipation in such boards, commissions or groups by lenders, guarantors, or groups of lenders and/or guarantors.
• LECOM does not assign a lender to any first-time borrower through financial aid packaging or any other means.
• LECOM recognizes that a borrower has the right to choose any lender from whom to borrow to finance his or her education. LECOM will not refuse to certify or otherwise deny or delay certification of a loan based on the borrower’s selection of a lender and/or guarantor.
• LECOM will not request or accept any offer of funds to be used for private education loans to students from any lender in exchange for providing the lender with a specified number or volume of Title IV loans, or a preferred lender arrangement for Title IV loans.
• LECOM will not request or accept any assistance with call center or financial aid office staffing.