Disclosures

Code of Conduct and Ethical Principles

 

These principles have been adopted from the National Association of Student Financial Aid Administrators Statement of Ethical Principles  
 

Code of Conduct

An institutional financial aid professional is expected to always maintain exemplary standards of professional conduct in all aspects of carrying out his or her responsibilities, specifically including 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. In doing so, a financial aid professional should:
 

  • Refrain from taking any action for his or her personal benefit.
  • Refrain from taking any action he or she believes is contrary to law, regulation, or the best interests of the students and parents he or she serves.
  • Ensure that the information he or she provides is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
  • Be objective in making decisions and advising his or her institution regarding relationships with any entity involved in any aspect of student financial aid.
  • Refrain from soliciting or accepting anything of other than nominal value from any entity (other than an institution of higher education or a governmental entity such as the U.S. Department of Education) involved in the making, holding, consolidating or processing of any student loans, including anything of value (including reimbursement of expenses) for serving on an advisory body or as part of a training activity of or sponsored by any such entity.
  • Disclose to his or her institution, in such manner as his or her institution may prescribe, any involvement with or interest in any entity involved in any aspect of student financial aid.
     

Ethical Principals

The primary goal of the financial aid professional is to help students achieve their educational potential by providing appropriate financial resources. To this end, this Statement provides the Financial Aid Professional with a set of principles that serves as a common foundation for accepted standards of conduct.
 

The Financial Aid Professional shall:
 

  • Be committed to removing financial barriers for those who wish to pursue post-secondary learning.
  • Make every effort to assist students with financial need.
  • Be aware of the issues affecting students and advocate their interests at the institutional, state, and federal levels.
  • Support efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school.
  • Educate students and families through quality consumer information.
  • Respect the dignity and protect the privacy of students, and ensure the confidentiality of student records and personal circumstances.
  • Ensure equity by applying all need analysis formulas consistently across the institution's full population of student financial aid applicants.
  • Provide services that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.
  • Recognize the need for professional development and continuing education opportunities.
  • Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.
  • Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.
  • Maintain the highest level of professionalism, reflecting a commitment to the goals of the National Association of Student Financial Aid Administrators.
     

Members of the Office of Student Financial Aid are prohibited from:
 

Engaging in any revenue-sharing arrangements on FFELP loans
 

Soliciting or accepting gifts other than of nominal de minimis value from lenders, guarantors, and servicers of education loans. The term gift means any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimis amount. The term includes a gift of 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.

The following are not considered gifts:

  • Standard material, activities, or programs related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
  • Food, refreshments, training, or informational Material furnished to an officer or employee of an institution, or to an agent, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such training contributes to the professional development of the officer, employee, or agent.
  • Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the institution if such terms, conditions, or benefits are comparable to those provided to all students of the institution.
  • Entrance and exit counseling services provided to borrowers to meet the institution's responsibilities for entrance and exit counseling as required by the HEA as long as the institution's staff are in control of the counseling and specific lender's products and services are not promoted.
  • Philanthropic contributions to an institution from a lender, servicer, or guarantor of education loans that are unrelated to education loans or any contribution from any lender, guarantor, or servicer that is not made in exchange for any advantage related to education loans.
  • State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
     

Contracting and consulting arrangements between an officer or employee of CCC and a lender of an affiliate of a lender, except that institutional employees who are not in the financial aid office can serve on the boards of directors of lenders, guarantors, and servicers of education loans if these employees do not have loan responsibilities or the institution has a has a written conflict of interest policy that clearly keeps the employee from participating in any decision of the board regarding education loans at the institution. Similarly, the bill allows, under certain conditions, officers, employees and agents of a lender, guarantor, and servicer of education loans to serve as a trustee of an institution.
 

Assigning, through award packaging or other methods, a first-time borrower's loan to a particular lender or refusing to certify, or delaying certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.
 

Participating in "opportunity pool loans" which is defined as requesting or accepting any offer of funds for private educational loans in exchange for the institution of higher education providing the lender with a specified number of loans or loan volume, or a preferred lender arrangement for Title IV loans. This does not include any private loan that is guaranteed by an institution (i.e., a recourse loan).
 

Receiving staffing assistance with financial aid or via a call center, but permits lenders to provide staffing services on a short-term, nonrecurring basis to assist institutions with financial aid-related functions during emergency situations or for office staff professional development or for providing educational counseling, financial literacy, or debt management materials to borrowers as long as such materials disclose to borrowers the name of the lender that provided or assisted in the preparation of the materials.
 

Receiving anything of value from the lender for participation on an advisory board, except reimbursement for reasonable expenses incurred in serving on such advisory board, commission or group.

 

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