Code of Conduct

1. Prohibition of Financial Ties to Institutions of Higher Education
   StuFund will not provide anything of value to an institution of higher education in exchange for any advantage or consideration related to our student loan activity with respect to the financial aid office, including but not limited to placement on any institution preferred student loan lender list.
2. Prohibition of Payments for Preferred Lender Status
   StuFund has always been and will always be a supporter of choice and competition within the education finance process. StuFund believes competition and choice on lender lists are critical, and StuFund supports the requirement of having a minimum of three lenders on each preferred student loan lender list, with at least two being unaffiliated lenders.
3. Prohibition of Gift and Trip Remuneration to Higher Education Employees StuFund will not provide anything of more than nominal value, as may be defined by Federal law, to any officer, trustee, director, employee or agent of an institution of higher education who is involved in the student lending process in such institution's financial aid office.
4. Advisory Board Compensation Rules
   StuFund will not provide anything of value, including reimbursement of expenses, to any officer, trustee, director, employee or agent of an institution of higher education involved in the student lending process in such institution's financial aid office.
5. Limitations on Staffing of Financial Aid Offices
   StuFund will not provide, without proper disclosure and transparency, staff for an institution of higher education's financial aid offices at any time where that employee has contact with students other than general debt counseling.
6. Disclosure of Range of Rates and Defaults
   Upon the request of any institution of higher education, StuFund will disclose information concerning the historic default rates of borrowers from said institution, and the rates of interest charged to borrowers from the institution.
7. Loan Resale Disclosure
   StuFund will fully and prominently disclose to students and their parents any agreements to sell loans to any lender.

Terms of the StuFund Student Loan Code of Conduct are subject to modification from time to time as changes occur in applicable laws and in the education finance industry.