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Code of Conduct for ���Ҵ�ý���߹ۿ���� Financial Aid Professionals and Other Covered Employees

In August of 2008, Congress reauthorized the Higher Education Opportunity Act (HEOA) and required that every institution participating in federal financial aid programs adopt and comply with a code of conduct that prohibits conflicts of interest and display this code prominently on its website. The provisions of the below Code of Conduct are intended to comply with ���Ҵ�ý���߹ۿ����’s obligations under this federal law (HEOA § 487(e)).

���Ҵ�ý���߹ۿ���� financial aid professionals (Office of Student Financial Services employees) as well as other College employees, officers, and agents with any responsibility for or oversight of federal financial aid and/or educational loan programs (covered employees) are expected to maintain exemplary standards of professional conduct in all aspects of carrying out their responsibilities. This includes all dealings with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized, or regulated activity.

All ���Ҵ�ý���߹ۿ���� financial aid professionals and other covered College employees are expected to adhere to the provisions of the below Code of Conduct as well as to the National Association of Student Financial Aid Administrator's (NASFAA’s) and (as updated or amended and applicable to their institutional roles). The obligations of this code are in addition to adherence with the College’s Statement of Professional Ethics, institutional Core Values, and the requirements of applicable local, state, and federal laws.

���Ҵ�ý���߹ۿ����’s financial aid professionals and other covered employees shall:

• Refrain from taking any action for their personal benefit.
• Refrain from taking any action they believe is contrary to law, regulation, or the best interests of the students and parents they serve.
• Ensure that the information they provide is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
• Be objective in making decisions and advising ���Ҵ�ý���߹ۿ���� regarding relationships with any entity involved in any aspect of student financial aid.
• Disclose to ���Ҵ�ý���߹ۿ���� in writing any involvement with or interest in any entity involved in any aspect of student financial aid.
• Not enter into any revenue-sharing arrangements with any education lender, loan servicer, or guarantor (collectively defined as “Lending Institution”). The College has no preferred lending agreement with any Lending Institution of private educational loans and does not maintain a preferred lender list.
  • Under this Code, a revenue-sharing arrangement includes circumstances where an institution recommends a Lending Institution or the loan products of a Lending Institution who provides or issues a loan in exchange for a fee or provision of material benefits, including revenue or profit sharing, to the institution, or employee or agent of the institution.
• Not direct borrowers to or assign, through award packaging or other methods, the borrower's private (alternative) education loan to a particular Lending Institution; or refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.
• Not solicit or accept any gift (nor any member of their family) from a Lending Institution. For purposes of this prohibition, the term "gift" means any gratuity, favor, discount, entertainment, hospitality, loan, services, transportation, meals, or other item, whether provided in kind, by purchase of a ticket, payment in advance or by reimbursement, having a monetary value of more than a de minimus amount ($25.00).
  • This provision shall not prohibit acceptance of (a) counseling services provided to borrowers, so long as the College controls such counseling; the counseling does not promote the products of a specific Lending Institution; and the Lending Institution personnel conducting the counseling do not represent themselves as associates of the College; or (b) standard educational materials, activities, training, or other programs related to default prevention or financial literacy, as long as the identity of the Lending Institution that prepared the materials is disclosed; or (c) reasonable food and refreshments provided as an integral part of such programs or activities, or in connection with a reception or information session given by a Lending Institution that is held in conjunction with a professional conference and is open to all conference attendees.
• Not maintain employment or a consulting arrangement with a Lending Institution or serve on an advisory board, commission, or group established by a Lending Institution or group of such institutions.
• Not request or accept from any Lending Institution any assistance with staffing the College’s financial aid office, admissions office, or call center; or otherwise represent themselves as an associate or representative of the College.
• Not permit a Lending Institution to use College logos or trademarks in the marketing of loans or services to students, prospective students, or parents in a way that suggests sponsorship by the College.
• Not request or accept from any Lending Institution any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for the institution 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.

(Updated: September 2022)