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Code of Conduct for Financial Aid Professionals

Institutional Operations

A. Revenue-Sharing Arrangements: The University will not enter into any revenue-sharing arrangement with any lender.

B. Interaction with Borrowers: The University will not assign a first-time borrower’s student loan, through award packaging or any other method, to a particular lender. The University will not refuse to certify, or delay the certification of, any student loan based on the borrower’s selection or a particular lender or guaranty agency.

C. Private Loans: The University will not request or accept from any lender any offer of funds to be used for private education loans to students in exchange for the University providing concessions or promises regarding providing the lender with (i) a specified number of federal loans; (ii) a specified federal loan volume; or (iii) a preferred lender arrangement for federal loans.

D. Co-Branding: The University will not permit an educational lender to use the University’s name, emblem, mascot, logo, or any other words, pictures, or symbols associated with the University to imply endorsement of private educational loans by that lender.

E. Staffing Assistance: The University will not request or accept from any lender any assistance with call center staffing or financial aid office staffing.

Financial Aid Office Employees

A. Conflicts of Interest: No employee may process any transaction related to his/her own personal financial aid eligibility or that of a relative or close personal friend.

B. Gifts: No employee may accept any gift from a lender, guaranty agency, or servicer of education loans. A gift to a family member of an employee or to any other individual based on that individual’s relationship with the employee shall be considered a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and the employee has reason to believe the gift was given because of the employee’s position at the University. A gift is any item or service provided to the employee of more than de minimus value.

Token awards from professional associations (state, regional, or national) that recognize professional milestones or service to parents and students, or scholarships for conference attendance or other professional development opportunities, may be accepted.
 
C. Prohibited Contracting Arrangements: No employee 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.

D. Advisory Board Compensation: No employee who serves on an advisory board, commission, or group established by a lender, guaranty agency, or group of lenders or guaranty agencies may receive anything of value from the lender, guaranty agency, or group of lenders or guaranty agencies in return for that service.

E. Reimbursement of Expenses: Expenses incurred while attending professional association meetings, conferences, or in connection with service on an advisory board, commission, or group must be paid by the University. Entertainment expenses may not be accepted.

F. Meals: Meals offered as a part of meetings, conferences, or other events may be accepted if all participants in the meeting or event are offered the meals or if the meals are included as a part of a registration fee.

G. Policy Violations: Violations of this policy by a University employee may result in disciplinary action, up to and including dismissal.