Code of Conduct
The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid personnel. In compliance with this requirement, the University of Notre Dame has created the following code of conduct based on the HEOA of 2008.
Other College employees, officers, and agents with responsibilities in respect to education loans also have to comply with this policy.
Conflict of Interest
No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.
- Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
- If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be fully and publicly disclosed. Borrowers will not be auto-assigned to any particular lender.
- A borrower's choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution, even if that lender is not included on the institution's preferred lender list.
- No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family), or from any entity doing business with or seeking to do business with the institution (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).
- Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.
Information Sharing
Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.
Institutional award notifications and/or other institutionally provided materials shall include the following:
- A breakdown of individual components of the institution's Cost of Attendance, designating all potential billable charges.
- Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.
- Standard terminology and definitions in accordance with guidance provided by NASFAA for award letter terms.
- Renewal requirements for each award.
All required consumer information is displayed in a prominent location on the institutional web site(s) and in any printed materials, easily identified and found.
Ban on Revenue-Sharing Arrangements
The University shall not enter into any revenue-sharing arrangement with any lender or other vendor working with any of its financial aid offices. The University shall not accept any fee or other material benefit in exchange for recommending a lender to its students.
Gift Ban
No University officer or employee with financial aid responsibilities shall solicit or accept a gift (e.g., a gift of services, transportation, lodging, or meals, provided by purchase of a ticket, payment in advance, or reimbursement) having a monetary value of more than a de minimus amount from a lender, guarantor, or servicer of education loans.
Contracting Arrangements Prohibited
No University officer or employee with financial aid responsibilities shall accept from any lender or lender affiliate any payment or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender.
Interaction with Borrowers
The University shall not automatically assign a particular lender to any borrower, and shall not refuse to certify or delay certification of any loan based on the lender or guarantee agency selected.
Prohibition on Offers of Funds for Private Loans
The University shall not request or accept from any lender an offer of funds to be used for private education loans in exchange for the University providing the lender with a specified number or volume of federal loans made or in exchange for placement on a preferred lender list.
Co-branding
The University prohibits any private educational lender from using the University’s name, emblem and logo as well as any words, pictures, or symbols associated with the University to imply endorsement of private education loans by that lender.
Ban on Staffing Assistance
The University shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Lenders, however, may provide professional development training to financial aid administrators, educational advising materials to borrowers, or assistance in state or federally-declared natural disasters.
Advisory Board Assistance
All employees with financial aid responsibilities shall be prohibited from receiving anything of value from a lender or guarantor in return for service on its advisory board. Reimbursement for reasonable expenses incurred in connection with such service, however, is permitted.