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Student Financial Assistance Code of Conduct

The Illinois College of Optometry takes seriously its responsibilities in administering student financial assistance. ICO strives to make the financial aid process transparent and fair to students and is committed to avoiding potential conflicts of interest with lenders. ICO complies with the requirements of Title IV of the federal Higher Education Act governing student financial assistance.

This Code of Conduct summarizes and describes the standards that ICO and its officers, agents, and employees must follow in their relationships with entities that make or guarantee loans to students, parents or others for the purposes of financing students’ higher education expenses (lenders).

ICO does not receive anything of value from a lender in exchange for providing the lender with advantages in marketing, offering, or making loans to ICO students or prospective students. Among the practices in which ICO does not engage are the following:


  • Engaging in revenue sharing, meaning any arrangement under which a lender pays a fee or provides other material benefits to the institution in exchange for the institution recommending the lender’s loan products.
  • Receiving computer hardware at below-market prices from a lender.
  • Receiving printing costs and services from a lender. 
  • At ICO, borrowers alone have the power to choose lenders and will receive timely loan certification regardless of the lender selected. ICO does not steer borrowers to particular lenders or delay loan certifications. Specifically, ICO does not:
              -Assign any first-time borrower’s loan to a particular lender. 
              -Refuse to certify or delay the certification of any loan based on the borrower’s selection of a particular lender or guaranty agency. 
              -Direct potential borrowers to any electronic Master Promissory Notes or other loan agreements that do not allow students to enter or select the lender code name for any lender offering the relevant loan through the relevant guaranty agency or electronic application service. 
  • ICO does not request or accept from lenders any offer of funds for private loans in exchange for providing concessions or promises to the lender for a specific number of Title IV loans made, insured, or guaranteed, or a specified loan volume, or a preferred lender arrangement. This prohibition covers “opportunity loans” and “opportunity pool loans.” 
  • ICO does not request or accept call center staffing or financial aid office staffing from lenders.  ICO does not utilize a preferred lender list and will not recommend any lender. 
  • Officers and employees who work in ICO financial aid offices or who otherwise have responsibilities related to educational loans may not:
               -Solicit or accept gifts, trips or lodging of more than nominal value from lenders, guaranty agencies, or loan servicers.
               -Enter into a contract or employment arrangement or otherwise accept compensation or financial benefits for consulting or other services relating to educational loans provided to or on behalf of a lender. 
               -Receive anything of value for service on the advisory board, commission, or other group established by a lender.


ICO will inform all officers, employees, and agents with responsibility for such loans of the code provisions on an annual basis. Violations of the code may result in discipline under applicable college policies and procedures, up to and including termination.