The Higher Education Opportunity Act (HEOA) requires educational institutions to develop and comply with a code of conduct that prohibits conflicts of interest in student financial services.  All Apollos University officers, employees, or agents who has responsibilities with respect to student educational loans must comply with the code of conduct.

The Code of Conduct establishes that:

1.Apollos University have no preferred lending agreement with any lender of private educational loans and as such no officer or employee of Apollos shall engage in the practice of recommending, promoting, or endorsing private educational loans for students attending Apollos.

2.Neither Apollos as an institution nor any individual officer, employee, agent, or affiliate employee shall enter into revenue-sharing arrangement with any lender. A revenue-sharing arrangement is defined as any arrangement between an institution and a lender under which the lender provides or issues 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.

3.No officer or employee of Apollos who is employed in the office of financial aid or who otherwise has responsibilities with respect to education loans, or agent who has responsibilities with respect to education loans, or any of their family members, shall solicit or accept any gift from a lender, guarantor, or servicer of education loans. For purposes of this prohibition, the term “gift” means any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimis amount. The term includes a gift of services, transportation, lodging, or meal, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.

4.No officer or employee of Apollos who is employed in the office of financial aid or who otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, shall not accept from any lender or affiliate of any lender a fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.

5.No officer or employee of Apollos who is employed in the office of financial aid or who otherwise has responsibilities with respect to education loans who serves on an advisory board, commission, or group established by a lender or group of lenders is prohibited from receiving anything of value from such entities, except the employee may be reimbursed for reasonable expenses incurred by the employee for serving on such boards, commissions, or groups.

6.Officers or employees of the office of financial aid shall not steer borrowers to particular lenders or delay loan certifications. For any first-time borrower, Apollos will not assign, through award packaging or other methods, the borrower’s loan to a particular lender. In addition, the university shall not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender.

7.Apollos shall not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing promise of a specific number of private education loans, a specific loan volume, or a preferred lender arrangement for such loans. An opportunity pool loan means a private education loan that involves a payment, directly or indirectly, by the institution of points, premiums, additional interest or financial support to the lender for the purpose of the lender extending credit to the student.

8.Apollos shall not request or accept from any lender any assistance with call center or financial aid office staffing,

As active institutional members of the National Association of Student Financial Aid Professionals (NASFAA), the Financial Aid employees at Apollos University prescribe to the NASFAA Code of Conduct. The Code of Conduct is intended to assist financial aid professionals in carrying out their obligations, particularly with regard to ensuring transparency in the administration of the student financial aid programs, and to avoid the harm that may arise from actual, potential, or perceived conflict of interest.