FINANCIAL AID CODE OF CONDUCT

About This Policy

Policy Statement

The North Central University Office of Student Financial Services serves students, families, and the community by providing financial aid information and resources to assist students in achieving their educational goals. The university is committed to providing quality financial aid services to its constituents while maintaining equality and accountability in the administration of public, institutional, and private financial aid funds.

To ensure trust in the university’s administration of financial resources to help students fund their education, all officers, employees, and agents of the university, including without limitation individuals who work with the university’s financial program and have responsibilities with respect to education loans, are required to abide by the following code of conduct.

North Central University personnel are expected to comply fully with all relevant laws, as well as with the university’s own high standards of integrity and quality. In addition to complying with specific laws or regulations that govern business activities, standards of fairness, honesty, and respect for the rights of others will govern conduct at all times.

• The university bans revenue sharing arrangements with any lender with respect to financial aid.
• The university bans employees who work with the university’s financial program receiving gifts from a lender, guaranty agency or loan servicer. No officer or employee of the university’s financial aid office (or an employee or agent who otherwise has responsibilities with respect to educational loans) may solicit or accept any gift from a lender, guarantor, or servicer of education loans.
• An officer or employee of the university who is employed in the financial aid office or who otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, will not accept from any lender or affiliate of any lender any gift or financial interest 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 prohibits steering borrowers to particular lenders or delaying loan certifications. For any first-time borrower, the university will not assign, through the award packaging or other methods, the borrower’s loan to a particular lender. In addition, the university will not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty agency
• The university will not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of federal loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement.
• The university prohibits staffing assistance from any lender any assistance with call center staffing or financial aid office staffing. However, a lender may provide professional development training, educational counseling materials (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, nonrecurring basis during emergencies or disasters.
• The university prohibits advisory board compensation for any employee of an university’s financial aid office (or employee who otherwise has responsibilities with respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor, or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board.

Any and all reimbursements received for any service on advisory boards, commissions, or other groups by lenders, servicers or guarantors must be reported annually to the Department of Education.

The university will:

• Provide student and parent borrowers with access to, and process loans for, all lenders of choice, including those not on a ‘lender list’.
• Offer the maximum federal aid eligibility and recommend that borrowers explore the benefits of federal financial aid before processing private/alternative loans.
• Provide ‘exit counseling’ to educate borrowers on their rights and responsibilities and provide information to enable them to determine which repayment option best fits their individual financial needs.
• Provide comprehensive financial aid counseling for students, prospective students, families and the community
• Establish and communicate priority dates, deadlines, and eligibility criteria via its website, email, publications, and presentations.
• Communicate the need to complete and submit required documents in a timely manner via email and the university’s student information system
• Communicate information regarding relationships with lenders and the criteria and process used to select lenders on any lender lists.
• Communicate the right and ability of borrowers to select a lender of their choice regardless of any lender list.

Violations of this policy may result in disciplinary action, up to and including dismissal.

Reason For Policy

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.  As a participant in the federal student aid programs, and more specifically the student loan programs, North Central University is required to develop, publish, administer, and enforce a code of conduct that complies with the Higher Education Opportunity Act of 2008. The obligations set out in this policy do not modify or supersede requirements previously set forth by other State and Federal law.

Policy Scope

The Code of Conduct for Financial Aid Professionals applies to all officers, employees, and agents of the institution who are responsible for student loans and financial aid.

Procedures

• There are no procedures associated with this policy.

Forms

• There are no forms associated with this policy.

Appendices

• There are no appendices associated with this policy.

Additional ContactS

Definitions

Conflict of Interest

A conflict of interest exists where there is a potential or actual divergence between the personal interests of a university member and that member’s obligation to uphold the interests and mission of the university. In a conflict of interest situation, an impartial observer might reasonably question whether actions or decisions taken by the university member on behalf of the university are influenced by consideration of personal interests. A conflict of interest depends on the situation, and not on the character or actions, of the individual.

Financial Interest

Anything of monetary value, including but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and the value of intellectual property rights (e.g., patents, copyrights and royalties from such rights).

Gift

For purposes of this Code, a “gift” is defined as any gratuity, favor, discount, entertainment, hospitality, loan, or other item having monetary value of more than a de minimis amount.  The HEOA provides some exceptions from its definition of “gift” including the following:

• Standard material, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy such as a brochure, a workshop, or training.
• Food, training, or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training.
• Favorable terms and benefits to a student employed by the institution as long as those same terms are provided to all students at the institution.
• Entrance and exit counseling as long as the institution’s staff are in control, and they do not promote the services of a specific lender.
• Philanthropic contributions from a lender, servicer, or guarantor or any contribution from a lender, servicer, or guarantor 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
• For purposes of this Code, a “gift” to a family member or an agent, or to any individual based on that individual’s relationship with the agent, is considered a gift if:
  • The gift is given with knowledge and approval of the agent and
  • The agent has reason to believe the gift was given because of the official position as an agent.

Opportunity Pool Loan

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 such 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.

Revenue-Sharing Agreement

An arrangement between the university and a lender under which (a) a lender provides or issues a loan to students attending the University or to their families; and (b) the university recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other materials benefits, including revenue or profit sharing, to the university or its employees.

Responsibilities

All University Community Members

• Report violations of this policy.

Student Financial Services

• Abide by this Code of Conduct.
• Administer the university’s financial aid program.

RELATED INFORMATION

Related Policies & Procedures

• University Policy: Conflicts of Interest and Commitment

Related Legislation

• Higher Education Opportunity Act of 2008 [HEOA § 487(a)(25)] and [HEOA § 487(e)]

History

Issued
2021-04-21