Some actions to take include:

First, if your college has a business conduct policy, make sure that you get a copy and read it. It should be the foundation of your approach to lenders since it will cover vendor policy. News coverage is useful in describing what not to do.

Second, if you have any serious questions, ask your college’s legal counsel. It may be expensive for colleges without in-house counsel, but it will be worth it.

Third, if you have relied on lenders for office services that you cannot manage within the office, let your college know that it will have to pick up those expenses. This might mean hiring permanently or temporarily. Distinguish between services that are related to compliance and those that are simply helpful to your clients. The former are critical.

Fourth, in FFELP and alternative loans, the key number seems to be three. Have at least three lenders for all of the various loans, student and parent. For FFELP, you must process a loan from any lender, even if it is not one of your recommended lenders.

Fifth, identify as broad a pool of potential lenders as possible. The MASFAA Fall Conference can be very useful in providing access to a number of lenders for 2008-2009. Spend time talking about the loans and collecting documentation. It is a first step in putting together a pool, and it is certainly a more efficient use of time for schools and lenders than individual office appointments.

Finally, as you narrow the pool, continue to keep clear records on borrower benefits and rates. The U. S. Department of Education will have, as one of its charges, the creation of a common disclosure template, but it will not be ready for this cycle or perhaps for even the next.

This is not an exhaustive list of "to-dos" but it is a starting point that may help move us into a new era.