3. At least 2 years' experience in an administrative capacity.

4. Knowledge of the literature in the field of method and technique in handling the adult educational problem, and identification with professional adult educational groups.

B. Trade and industrial courses: The chief instructor or principal of each trade and industrial course or subject taught shall have had at least the following educational preparation and experience:

1. Four years' study beyond high school with a major in the subject taught and 2 years' teaching, or

2. A high-school education and 6 years' practical experience and at least 1 year teaching in the trade or vocation taught, or

3. A high-school education and a combination of at least 6 years of higher education or teaching in the trade and practical experience in the trade or vocation taught.

4. Same as 4, under "Educational director."

C. Professional engineering and business courses: The chief instructor or principal of each professional, engineering, and business course taught shall have had at least the following educational preparation and experience:

1. Four years beyond high school with a major in the subject taught or equivalent training such as a C. P. A. certificate for the business course, and 2. Two years of practical experience or teaching experience in the subject taught, or graduate training and 1 year of practical experience, and

3. Same as 4, under "Educational director."

D. All other instructors are required to have:

1. Competency in the use of written English.

2. Technical information and skills in the trade or vocational subject taught. 3. At least 1 year of teaching experience.

IV. CURRICULUM

Each course of instruction offered shall consist of:

A. A preliminary lesson or set of instructions on "how to study" by the homestudy method, or adequate instruction on how to study each lesson assignment. B. Textual or lesson materials which are:

1. Adequate in that they cover the subject as fully and as thoroughly as announced.

2. Accurate in that they are well authenticated.

3. Current in that they represent reliable modern information on the subject. 4. Presented in a simple, clear, interesting, and logical manner so that the student can grasp the important points readily.

5. Illustrated with photographs, cuts, and drawings which clarify the explanations and not simply adorn the text.

6. Printed in such a manner as to contribute to ease of study.

C. Instructional service on each lesson or unit assignment consisting of: 1. A series of examination questions or problem assignments which thoroughly stress the important phases of the subject presented and which require a demonstration of the student's ability or skill in applying the information secured.

2. A personalized correctional service pointing out the errors, directing the student to sources of correct information, as well as supplying additional explanations and supplementary instructional material when necessary.

D. A definite system of encouragement and stimulation of students so that study may begin promptly and written reviews or examinations may be returned to the school for correction with reasonable regularity.

V. PLANT AND EQUIPMENT

A. The office space and educational facilities and equipment used by each school shall be adequate to meet all needs for instruction and the keeping of academic and other records.

B. If shop or class work is offered in connection with the educational program, all teaching equipment should be up-to-date and sufficient in amount and kind to make for successful learning and instruction.

VI. SALES PROMOTION AND ENROLLMENTS

A. All advertisements, catalogs, letters, contract forms, sales literature, approved sales talks, etc., must conform to the Fair Trade Practice Rules for Private Correspondence Schools approved by the Federal Trade Commission.

B. All enrollment forms or accompanying forms are required to contain in substance the following information:

1. The fact that as soon as the enrollment application is accepted by the home office of the school it becomes a contract between the student or guarantors and the school.

2. A description of: (a) The course of study; (b) the various textual materials and experimental equipment supplied to the student; or (c) the main features of the course of study and services to be rendered with it enumerated either in a body of the agreement or in the official literature of the school and given to the student when the enrollment form is filled out.

3. The student's obligation to the school, terms, and dates of payment, etc. 4. If any special agreements are included, such as refund, etc., the conditions of same must be set forth in a clear, simple manner and with due prominence. 5. To assist the school in accepting only enrollments of logical prospects, each application form or accompanying form should contain, among other items, blank spaces for the following information: (a) Age of applicant; (b) physical defects, if any, of the applicant to insure that he has no disabilities which would interfere with his ability to pursue the trade or vocation for which training is sought; (c) the amount of previous education of applicant; (d) the amount and character of previous vocational experience of applicant; and (e) record of employment or other references to insure the applicant's ability to pay the required tuition fee.

C. Each student shall be furnished with a duplicate copy of the enrollment form which he signs, either at the time of his signing same or when such application is accepted by the school.

D. Personal selling:

1. It is required of all schools employing a field organization to secure enrollments that they supply such representatives with: (a) Definite instructionsgiven in printed form-regarding the school, its course or courses of instruction, services rendered, general policy, etc.; and (b) an approved demonstration or pattern of sales presentation and also some training in vocational guidance for guiding representatives in aiding prospect in selection of course.

2. To schools employing a field organization to secure enrollments it is recommended: (a) That all field representatives be bonded; (b) that all enrollments taken by a new representative be "verified" until the quality of his business shall have become established; and (c) that there be adequate supervision of all representatives and that a periodic check of their sales presentation be made.

A. General:

VII. COLLECTIONS

1. Each school should have an efficient collection department for the billing, collecting, and handling of its current and delinquent accounts.

2. Whatever collection system may be utilized by a school, it should be operated with dignity, courtesy, and tact as well as in accordance with sound business procedure.

3. The predominant characteristic of any method utilized for the collection of delinquent accounts should be "resale."

B. Adjustments and settlements:

1. Every school should recognize that there may be sound reasons why an enrolled student may not be able to pursue a course of training with benefit to himself, irrespective of the fact that he may have contracted to do so; and, on request he should receive fair and just consideration in the modification of his contract. The following cases are typical: (a) A bona fide change of job or life objective toward which the course of study could make little or no contribution; (b) a proven physical disability which was acquired after enrollment and which would handicap or disqualify the student from carrying on in the field or vocation selected; (c) a demonstrated lack of ability to assimilate the training materials furnished; (d) the drafting or enlistment in the armed forces of his country or the enrollment and attendance in any regular resident public college, university, or high school.

2. Every school should have a fixed policy for making equitable adjustments and settlements upon request and make same available to enrolled students when such request is presented. Schools which offer more than one course should have a fixed policy for transferring the student from one course to another.

C. Collection agencies:

1. When and if member schools turn over delinquent accounts to collection agencies or attorneys, the National Home Study Council shall hold such member schools responsible for the acts of their agents when such acts are not in harmony with the council's standards of policy.

TRADE PRACTICE RULES FOR PRIVATE HOME-STUDY SCHOOLS APPROVED BY FEDERAL TRADE COMMISSION, NOVEMBER 2, 1936

These rules promulgated by the Federal Trade Commission are designed to foster and promote fair competitive conditions in the interest of industry and the public. They are not to be used, directly or indirectly, as part of or in connection with any combination or agreement to fix prices, or for the suppression of competition, or otherwise to unreasonably restrain trade.

GROUP I

The unfair-trade practices which are embraced in group I rules are considered to be unfair methods of competition within the decisions of the Federal Trade Commission and the courts, and appropriate proceedings in the public interest will be taken by the Commission to prevent the use of such unlawful practices in or directly affecting interstate commerce.

Rule 1.-The making, or causing or permitting to be made or published, any false, untrue, or deceptive statement or representation, by way of advertising or otherwise, concerning home-study schools, their activities in attempting to enroll students, or concerning the character, nature, quality, value, or scope of any course of instruction or educational service offered, or in any other material respect, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 2.-The making of false, untrue, or deceptive statements or representations regarding actual or probable earnings or opportunities in any vocation, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 3.-The making of false, untrue, or deceptive statements or representations regarding the opportunities in any vocation or field of activity as a result of the completion of any given course of instruction or educational service, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 4.-The making of false, untrue, or receptive statements or representations as to services to be rendered in connection with the securing or attempting to secure employment for students, or as to the influence or connection of any school or schools with any branch, department, or establishment of the United States Government with the tendency, or capacity to mislead or deceive students, prospective students, or the public, is an unfair-trade practice.

Rule 5.-The making or false, untrue, or deceptive promises or representations regarding a job or a raise in pay upon completing a certain course of instruction or portion thereof, with the tendency or capacity to mislead or deceive students, prospective students, or the public,, is an unfair trade practice.

Rule 6.-Representing an offer to be limited as to time or otherwise when such is not the fact, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 7.-Representing an offer as "special" when it is in fact a "regular" offer, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

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Rule 8.—Offering courses of instruction at prices purported to be reduced from what are in fact marked-up or fictitious prices, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 9.-It is an unfair trade practice for any member of the industry to use, directly or indirectly, any so-called money back guaranty, refund agreement, or other similar guaranty, agreement, or contract between school and student, which (a) is conditioned upon the student taking or passing, or having the opportunity to take or pass, a future Government or civil-service examination or test, or any other form of future examination or test given by any organization not affiliated with the school; or (b) is conditioned upon the student being placed upon a Government or other eligible list; or (c) is conditioned upon the student securing or having the opportunity to secure employment within the field of training pursued; or (d) is conditioned upon any other contingency; and

which has the capacity, tendency, or effect of misleading or deceiving students or prospective students because of the text of such guaranty, agreement, or contract, or because of the representations regarding the same, or because of the circumstances or other conditions of its use, or which otherwise involves deception, misrepresentation, bad faith, or the deceptive concealment of pertinent facts.

Rule 10.-Making offers of scholarships or partial scholarships in such manner as to mislead or deceive students or prospective students into the belief that such offers are bona fide, when they are in fact not bona fide, is an unfair trade practice.

Rule 11.-Representing any commodity or service as "free" when in fact such commodity or service is regularly included as part of the course of instruction or service, with the tendency or capacity to mislead or receive students, prospective students, or the public, is an unfair trade practice.

Rule 12.-The defamation of competitors by falsely imputing to them dishonorable conduct, inability to perform contracts, questionable credit standing, or by other false representations, or the false disparagement or the character, nature, quality, value, or scope of their courses of instruction or educational services or in any other material respect, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is a unfair trade practice. Rule 13.-The use of any name, title, or other designation, by way of advertising or otherwise, having the tendency or capacity to mislead or deceive students, prospective students, or the public as to the character of the institution, its courses of instruction, or its influence in obtaining employment for students, is an unfair trade practice.

Rule 14.-For any member of the industry to issue any certificate or diploma, or to confer any degree, which misrepresents the course of study or instruction covered or completed, or the accomplishments or standing of the student receiving such certificate, diploma, or degree, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 15. Falsely representing the character or scope of any course of instruction or service offered, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 16.-The making of false, untrue, or deceptive statements or representations, through advertising or otherwise, that a certain individual or individuals are bona fide members of the faculty of a school or are members of its advisory board or authors of its instruction material, or the making of misleading statements or representations as to the value of any former connection with the United States Government as an aid to securing employment, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 17.-The false representation, through advertising or otherwise, that students are given personal instruction by the head of the institution or a department head thereof, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 18.-The use of "help wanted" or other employment columns in newspapers or other publications to get in touch with prospective students in such manner as to mislead or deceive such prospective students into the belief that a job is offered is an unfair trade practice.

Rule 19. The use of "blind" advertisements or sales literature to attract prospective students when such advertising or literature fail to set forth that courses of instruction or other educational services are being offered in such manner as to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 20.-The use of misleading or deceptive language in any form with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 21.-The use of the word "guarantee" or other word or words of similar import in connection with "money back" agreements, in such manner as to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 22.-In the collection of tuition fees, the use of papers simulating or counterfeiting court documents in such manner as to mislead or deceive students is an unfair trade practice.

Rule 23.-The use of a photograph cut, engraving, or illustration in catalogs, sales literature, or otherwise in such manner as to convey a false impression as

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to the size, importance, or location of the offices occupied by a private homestudy school, or as to such school's equipment, with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 24.-The use of pictures or illustrations of Uncle Sam, the National Capitol, or any pictures, illustrations, or devices of similar character or the use of the name or title of any present or former Government official activity, branch, department, or establishment of the Government in such manner as to mislead or deceive students, prospective students, or the public into the erroneous belief that the institution or its instructors have official relationship or connection with the United States Government, or into the erroneous belief that the training or services offered has the approval or endorsement of the United States Government or any branch thereof, is an unfair trade practice.

Rule 25.-Falsely representing, directly or indirectly, through advertising or otherwise, that a school is operated "not for profit," with the tendency or capacity to mislead or deceive students, prospective students, or the public, is an unfair trade practice.

Rule 26.-Willfully inducing the enrollment or retention of a student for any course of instruction or training for a job or position for which the student is manifestly unfit by reason of educational or permanent physical disqualification, or other material disqualification, is an unfair trade practice.

GROUP II

The trade practices embraced in Group II do not, per se, constitute violations of law. They are considered by the industry either to be unethical, uneconomical, or otherwise objectionable, or to be conducive to sound business methods which the industry desires to encourage and promote. Such rules, when they conform to the above specifications and are not violative of law, will be received by the Commission, but the observance of said rules must depend upon and be accomplished through the cooperation of the members of the industry concerned, exercised in accordance with existing law. Where, however, such practices are used in such manner as to become unfair methods of competition in commerce or a violation of any law over which the Commission has jurisdiction, appropriate proceedings will be instituted by the Commission as in the case of violation of group I rules.

Rule A.-"Money-back" agreements, so-called, or other similar contracts between school and student, should state plainly the conditions under which tuition or other moneys will be refunded, and such agreements of contrast should contain no conditions intended to deceive, hamper, or harass the student and prevent a refund to him of tuition to which he may be entitled under the terms of the contract.

Rule B.-It is the judgment of the industry that the sales representatives of all schools be selected primarily on a basis of ability and integrity and that each representative be given an adequate preliminary training and be bonded by an approved bonding company or by adequate personal sureties conditioned upon the faithful performance of his financial duties before being authorized to secure student enrollment.

Rule C.-It is the judgment of the industry that all schools should at or prior to the time of enrollment for any course of study or service provide each student enrolled therein with literature, by means of catalog, correspondence or other writing, clearly setting forth the nature, scope, number, and character of lesson assignments, and the terms upon which such course of study or service is sold. Rule D.-It is the judgment of the industry that the members thereof should exercise careful supervision over their sales representatives so as to guard against any misrepresentation by such representatives regarding advantages or opportunities or other matters pertinent to enrolling students or prospective students, whether or not the same be set forth in the contract between school and student. Enforcement of rules.-A committee on trade practices, comprising five members, is hereby created by the industry to cooperate with the Federal Trade Commission and to perform such acts as may be legal and proper to put these rules into effect. By direction of the Commission,

OTIS B. JOHNSON, Secretary.

Procedure in filing complaint.-The home-study industry has designated as permanent chairman of the above enforcement committee, Dr. J. S. Noffsinger, 839 Seventeenth Street NW., Washington. D. C., to whom all complaints regarding violations of this code may be sent. When it is desired to file complaint regarding a violation of any part of this code such complaint should be submitted as follows: 1. All complaints must be presented in writing and signed by the complainant.