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Code of Conduct

PURPOSE

The primary goal of the College’s financial aid office is to help students achieve their educational potential by providing or directing students toward appropriate financial resources. In doing so, staff members of the Caldwell University Office of Financial Aid shall continue to conduct themselves in an ethical and professional manner, in accordance with the “Statement of Ethical Principles” set forth by the National Association of Student Financial Aid Administrators and other requirements set forth in this policy.

STATEMENT OF ETHICAL PRINCIPLES

A. The College’s Office of Financial Aid is a member of the National Association of Student Financial Aid Administrators (“NASFAA”), which is the professional organization serving College financial aid officers. In furtherance of its organization and membership, NASFAA has adopted a Statement of Ethical Principles which governs the conduct of its members. That Statement of Ethical Principles is hereby incorporated into this policy and is applicable to employees of the College serving within the Office of Financial Aid and their superiors.

THE FINANCIAL AID PROFESSIONAL SHALL:

  1. be committed to removing financial barriers for those who wish to pursue post-secondary learning;
  2. make every effort to assist students with financial need;
  3. be aware of the issues affecting students and advocate for their interests at the institutional, state, and federal levels;
  4. support efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school;
  5. educate students and families through quality consumer information;
  6. respect the dignity and protect the privacy of students, and ensure the confidentiality of student records and personal circumstances;
  7. ensure equity by applying all need analysis formulas consistently across the institution’s full population of student financial aid applicants;
  8. provide services that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status;
  9. recognize the need for professional development and continuing education opportunities;
  10. promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession;
  11. commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof;
  12. maintain the highest level of professionalism, reflecting a commitment to the goals of the National Association of Student Financial Aid Administrators.

CODE OF CONDUCT

A. In addition to the above statement of ethical principles, employees of the College’s Office of Financial Aid, as well as all other College employees, who serve as their superiors, shall also adhere to the following requirements. Trustees of the College, since they are not employees of the college, are not restricted by the following.

  1. The College shall require and ensure that no officer, director, employee, or agent of the College accepts anything of more than nominal value on his or her own behalf or on behalf of another from or on behalf of a lending institution. This provision shall not be construed to prohibit any officer, director, employee, or agent of the College from conducting non-College business with any lending institution. As used in this policy, a lending institution shall be defined as:
    1. any entity that itself or through an affiliate engages in the business of making loans to students, parents, or others for purposes of financing higher education expenses or that securitizes such loans; or
    2. any entity, or association of entities, that guarantees education loans; or
    3. any industry, trade, or professional association that receives money from any entity described above in subsections 1(a) and 1(b). Nothing in this policy shall prevent the College from holding membership in any nonprofit professional association.
  2. The prohibition set forth in Paragraph III.A.1 above shall include, but not be limited to, a ban on any payment or reimbursement by a lending institution to a College employee for lodging, meals, or travel to conferences or training seminars.
  3. The College shall prohibit any officer, director, employee, or agent of the College from receiving any remuneration for serving as a member or participant of an advisory board of a lending institution, or receiving any reimbursement of expenses for so serving; provided, however, that participation on advisory boards that are unrelated in any way to higher education loans shall not be prohibited.
  4. The College may not accept on its own behalf anything of value from any lending institution in exchange for any advantage or consideration provided to the lending institution related to its education loan activity. This prohibition shall include, but not be limited to: a. “revenue sharing” by a lending institution with the College; and b. the College’s receipt from any lending institution of any computer hardware for which the College pays below market prices; and c. printing costs or services. Notwithstanding anything else in this paragraph, the College may accept assistance as contemplated in 34 CFR §682.200(b)(5)(i).
  5. In the event that the College promulgates a list of preferred or recommended lenders or similar ranking or designation (“Preferred Lender List”), then the following procedures shall be followed.
    1. Every brochure, Web page, or other document that sets forth a Preferred Lender List shall clearly disclose the process by which the College selected lenders for said Preferred Lender List, including but not limited to the criteria used in compiling said list and the relative importance of those criteria. If such a disclosure is not practicable on a brochure, the ability to find such disclosure on the College’s Web page or through other documentation provided by the Office of Financial Aid shall be prominently displayed as part of the brochure; and
    2. Every brochure, Web page, or other document that sets forth a Preferred Lender List or identifies any lender as being on said Preferred Lender List shall state in the same font and same manner as the predominant text on the document that students and their parents have the right and ability to select the education loan provider of their choice, are not required to use any of the lenders on said Preferred Lender List, and will suffer no penalty for choosing a lender that is not on said Preferred Lender List; and
    3. The College’s decision to include a lending institution on any such list and the College’s decision as to where on the list the lending institution’s name appears shall be determined solely by consideration of the best interests of the students or parents who may use said list without regard to the pecuniary interests of the College; and
    4. The constitution of any Preferred Lender List shall be reviewed no less than annually.
    5. No lending institution shall be placed on any Preferred Lender List unless the said lender provides assurance to the College and to student and parent borrowers who take out loans from said lending institution that the advertised benefits upon repayment will continue to inure to the benefit of student and parent borrowers regardless of whether the lending institution’s loans are sold; and
    6. No lending institution that has an agreement to sell its loans to another unaffiliated lending institution shall be included on any Preferred Lender List unless such agreement is disclosed therein in the same font and same manner as the predominant text on the document in which the Preferred Lender List appears; and
    7. No lending institution shall be placed on any one of the College’s Preferred Lender Lists or in favored placement on any one of the College’s Preferred Lender Lists for a particular type of loan, in exchange for benefits provided to the College or to the College’s students in connection with a different type of loan.
  6. The College shall not allow and shall ensure that no employee or other agent of a lending institution is ever identified to students or prospective students of the College or their parents as an employee or agent of the College. No employee or other agent of a lending institution may staff the College financial aid offices at any time.
  7. The College shall not link or otherwise direct potential borrowers to any electronic master promissory notes or other loan agreements that do not allow students to enter the lender code or name for any lender offering the relevant loan.
  8. The College shall not arrange with a lending institution to provide any loan of any nature if the provision of such loans prejudices any other borrower