900.5 - Financial Aid Code of Conduct
University Group Policy #900.5
I. Policy Statement
Winston-Salem State University (hereinafter referred to as “University”) is committed to maintaining the integrity of the administration of its financial aid program. In order to participate in Title IV Programs and in compliance with the Higher Education Opportunity Act, this Code of Conduct is established to address potential issues relating to conflicts of interest.
- The University, its agents and employees are prohibited from having or creating conflicts of interest with respect to educational loans. Conflicts of Interest include but are not limited to paragraphs 2- 9 herein.
- The University, its agents and employees are prohibited from and will not participate in revenue-sharing arrangements with educational lenders.
- The University, its agents and employees will not accept gifts from a lender, guarantor, or servicer of loans. Gifts include any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount, including services, transportation, lodging, and meals. No officer, employee in the financial aid office, or agent with responsibility for loans, shall accept any gifts except for the following: (1) materials or programs related to loans, default aversion, etc.; (2) food, refreshments, training, or informational material furnished as an integral part of a training program; (3) favorable terms, conditions on a loan provided to a student-employee, if the benefits are comparable to those provided to all students; (4) entrance and exit counseling services, as long as institutional staff maintain control and the products and services of any lender are not promoted, or (5) philanthropic contributions to an institution that are unrelated to education loans and not made in exchange for any advantage related to education loans.
- The University, its agents and employees shall not enter into contractual or consulting arrangements with a lender, guarantor or servicer or receive any fees, payments or other financial benefits for consulting services. This prohibition does not apply to: (1) an employee or officer who is not employed in the financial aid office and does not have responsibilities for loans may perform paid or unpaid service on a board of directors of a lender, guarantor or servicer; (2) an employee or officer who is not employed in the financial aid office but does have responsibilities for loans may perform paid or unpaid service on a board of directors of a lender, guarantor or servicer if the institution has a conflict of interest policy that requires them to recuse themselves from decisions regarding the institution, or (3) an officer or employee of a lender, guarantor, or servicer may serve on a board of directors of an institution if the institution’s conflict of interest policy requires them to recuse themselves from decisions regarding student lending.
- The University, its agents and employees will not assign a first-time 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 lender.
- The University, its agents and employees are prohibited from asking for or accepting any offer of funds to be used for private educational loans or opportunity pool loans in exchange for providing a lender with loan volume or a preferred lender arrangement.
- The University, its agents and employees will not request or accept call center or financial aid office staffing assistance from a lender. The University, however, may accept: (1) professional development training, (2) educational counseling, financial literacy, or debt management materials, and (3) short-term, non-recurring staffing assistance to help during emergencies.
- The University, its agents and employees are prohibited from accepting any funds to be used for private education loans in exchange for the University providing concessions to a private lender. payments, except for reimbursement for reasonable expenses, by lenders or guarantors to financial aid office employees or others with responsibilities for education loans.
- Any University employee with responsibilities with respect to financial assistance at the institution, who serves on an advisory board or commission of a lender or guarantor, may not accept anything of value from the lender or guarantor expect reimbursement for the reasonable expenses of serving on the board or commission.
- The University will prominently publish this Code of Conduct on its web site, and will administer and enforce it.
- The University will administer and enforce this Code by requiring that all of its officers, employees, and agents.
This Code of Conduct shall apply to all employees and agents with responsibilities to education loans or financial aid administration.
Failure to comply with this policy will be grounds for disciplinary action, up to and including dismissal.
Responsible Division: Provost & Vice Chancellor for Academic & Student Affairs
Authority: Board of Trustees
- Adopted June 19, 2009