Financial Aid Code of Conduct
The mission of the Financial Aid Office is to provide the best possible financial assistance to students. Personal integrity and the highest ethical standards are essential to that mission. The university’s ethical code of conduct emphasizes general principles to guide employees; the following specific guidelines apply to employees working with student loans. None of the following prohibited activities have ever been practiced at Utah State University, but it is helpful to be aware of them to help avoid even the appearance of a conflict of interest.
Employees of the Financial Aid Office are prohibited from:
- engaging in any revenue-sharing arrangements on student loans.
- soliciting or accepting gifts from lenders, guarantors, and servicers of education loans. The term gift is defined as “any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount.” This can include 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.
- making contracting and consulting arrangements with a lender or an affiliate of a lender.
- 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).
- accepting staffing assistance to administer financial aid, either in person or via a call center. (Lenders may 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.