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Lending Code of Conduct

The ĤƵ Student Lending Code of Conduct

The ĤƵ is committed to providing students and their families with the best information and processing alternatives available regarding student borrowing.  In support of this commitment and in an effort to rule out any perceived or actual conflict of interest between the ĤƵ officers, employees or agents and education loan lenders, the ĤƵ has adopted the following Code of Conduct in accordance with the requirements of the Higher Education Opportunity Act (HEOA § 487(e)).  The University shall publish this Code on its website and annually inform those with responsibilities for student educational loans. 

  • The ĤƵ participates in the Federal Direct Stafford, Federal Direct Undergraduate PLUS, and Federal Direct Graduate PLUS Loan Programs where the Federal Government is the only possible source of funding.  Therefore, the Code of Conduct applies to Private Educational Loans.
  • The ĤƵ prohibits any real or apparent conflicts of interest between its officers, employees or agents and educational load lenders arising from student lending transactions.
  • The ĤƵ does not participate in any revenue-sharing arrangements for private educational loans with any lender.  For purposes of this paragraph, the term ‘revenue-sharing arrangement’ means an arrangement between an institution and a lender under which (i) a lender provides or issues a loan that is made, insured, or guaranteed to students attending the institution or to the families of such students; and (ii) the institution recommends the lender or the load products of the lender and in exchange, the lender pays a fee or provides other material benefits, including revenue or profit sharing, to the institution, an officer or employee of the institution or any agent
  • The ĤƵ does not permit any officer, employee or agent of the school who is employed in the financial aid office or is otherwise involved in the administration of education loans to solicit or accept any gifts greater than a nominal value from any lender, guarantor or servicer.
  • The ĤƵ does not permit any officer, employee or agent of the school who is employed in the financial aid office or is otherwise involved in the administration of education loans to accept any fee, payment or other financial benefit (including a stock purchase option) from a lender or affiliate of a lender as compensation for any type of consulting arrangement or contract to provide services to a lender or on behalf of a lender relating to education loans.
  • The ĤƵ does not permit any officer, employee or agent of the school who is employed in the financial aid office or is otherwise involved in the administration of education loans to accept any thing of value from a lender, guarantor, or group of lenders and/or guarantors in exchange for service on an advisory board, commission or other group established by such a lender, guarantor group of lenders and/or guarantors. ĤƵ does allow for the reasonable reimbursement of expenses associated with participation in such boards, commissions or groups by lenders, guarantors, or groups of lenders and/or guarantors.
  • The ĤƵ does not assign a lender to any financial aid package for Private Educational Loans. 
  • The ĤƵ recognizes that a borrower has the right to choose any lender from which to borrow to finance his/her education. The ĤƵ will not refuse to certify or otherwise deny or delay certification of a loan based on the borrower’s selection of a lender and/or guarantor.
  • The ĤƵ will not request or accept any offer of funds to be used for Private Education Loans to students from any lender in exchange for providing the lender with a specified number or volume of Title IV loans, or a preferred lender arrangement for Title IV loans.
  • The ĤƵ will not use any lender for any financial aid office or call center assistance.
Sanctions

University employees are expected to use good judgment, professional commitment, and the highest standards of ethics to protect themselves and the University from real and/or apparent conflicts of interest.  Failure of an employee to disclose and resolve or avoid conflicts of interest in accordance with University Policy may result in disciplinary sanctions under the applicable provisions of the Human Resources Handbook for Staff and Administrators.

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