Code of Conduct
The purpose of this policy is to prohibit conflicts of interest in situations involving student financial aid and to establish standards of conduct for employees with responsibility for student financial aid.
This Policy applies to all employees who work in the Office of Financial Aid and all other University employees who have responsibilities related to education loans or other forms of student financial aid.
No officer, trustee, employee or agent who has responsibilities with respect to student financial aid or education loans shall solicit or accept any gift from a lender, guarantor, or servicer of education loans.
Gifts include any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a nominal amount, including services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.
Gifts to a family member of an officer or employee or agent shall be considered a gift to the officer, employee or agent if the gift is given with the knowledge, and acquiescence of the officer, employee or agent, and the officer, employee or agent has reason to believe the gift was given because of his or her official capacity.
Interaction with Borrowers
The University shall not assign, through award packaging or other methods, the borrower’s loan to a particular lender, or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
Preferred Lender List
The University will participate in the William D. Ford Direct Loan Program which provides student loans directly from the United States Department of Education. The University will not publish a preferred lender list that gives any lender an advantage in securing student loans from University students.
No University officer, employee or agent who has responsibilities with respect to student financial aid or education loans shall accept from any lender or affiliate of any lender any 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.
The University shall not enter into revenue-sharing arrangements with lenders or guarantors.
The term “revenue-sharing arrangement” means an arrangement between an institution and a lender under which (a) a lender provides or issues a loan that is made, insured, or guaranteed to students attending the institution or to the families of such students, and (b) 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 an officer, employee or agent.
The University shall not request or accept from a lender or guarantor any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises regarding providing the lender with (a) a specified number of loans made, insured, or guaranteed, (b) a specified loan volume of such loans, or (c) a preferred lender arrangement for such loans. The term “opportunity pool” means a private education loan made by a lender to a student attending the institution or the family member of such a student that involves a payment, directly or indirectly, by the institution of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family.
The University shall not request or accept from any lender or guarantor any assistance with staffing of the financial aid office or student loan processing. The University shall not accept any computer hardware from a lender or guarantor for which the University pays below-market prices or offers to print financial aid materials from a lender or guarantor.
No officer, trustee, employee or agent who has responsibilities with respect to student financial aid or education loans and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, shall accept anything of value, including reimbursement for expenses, from the lender, guarantor, or group of lenders or guarantors for such service. For additional guidance regarding board service, refer to the University’s Gift Policy.
Conflict of Interest Policy
Officers, employees and agents who have responsibilities with respect to student financial aid
and education loans shall also comply with the University’s Conflict of Interest Policy.