Student Financial Services Student Loan Code of Conduct

1. The University shall not enter into any revenue-sharing arrangement with any lender.
2. No officer or employee of the University who is employed in Student Financial Services or who otherwise has responsibilities with respect to education loans shall solicit or accept any gift (any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount) from a lender, guarantor, or servicer of education loans.
3. An employee who is employed in the Student Financial Services Office of the University or who otherwise has responsibilities with respect to education loans, shall not 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.
4. The University shall not for any first-time borrower, 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.
5. The University shall not request or accept from any lender any offer of funds to be used for private education loans (as defined in section 140 of the Truth in Lending Act), including funds for an opportunity pool loan, to students in exchange for the University providing concessions or promises regarding providing the lender with:
   • A specified number of loans made, insured, or guaranteed under this title;
   • A specified loan volume of such loans; or
   • A preferred lender arrangement for such loans
6. The University shall not request or accept from any lender any assistance with call center staffing or Financial Aid staffing.
   • Assistance will be permitted for the following instances:
     • Professional development training for financial aid administrators;
     • Providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials
7. Any employee who is employed in Student Financial Services, or who otherwise has responsibilities with respect to education loans or other student financial aid of the University, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, shall be prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.

In addition to the items above, as a member of the National Association of Student Financial Aid Administrators (NASFAA), the University also follows the standards established in NASFAA’s Statement of Ethical Principles and Code of Conduct for Institutional Financial Aid Professionals.

This code of conduct has been adopted to address participation in the Title IV loan program as well as participation in a preferred lender arrangement.