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Code of Conduct

Scope and Applicability

The code of conduct applies to all Office of Financial Aid and Scholarships (“OFAS”) employees, including, but not limited to OFAS Loan Officers, acting pursuant to the duties and responsibilities of their positions with the College.

Code of Conduct

  1. OFAS employees shall not take actions or make any decisions in the course of their employment that are for the employees’ own personal benefit or that could reasonably be perceived as conflicting with the Employees’ obligations to carry out their duties in the best interests of the College and the students they serve. Information provided by OFAS employees in the course of their duties will be accurate and unbiased and will not be influenced by actual or potential personal gain.
  2. OFAS employees shall not award any financial aid or scholarships to themselves, their family members, or any persons with whom they have or have had a close personal relationship.
  3. OFAS shall not create, distribute, or participate in a preferred lender list, and OFAS employees are not permitted to recommend particular lenders, even when asked to do so by prospective student borrowers. OFAS will process a student’s request for a private loan without prejudice and solely for the benefit of the student requesting the loan. Student borrowers shall initiate the approval process with the banking institutions of their choice and are never auto-assigned or directed to any particular lender by OFAS.
  4. OFAS will not deny, impede, or unnecessarily delay awarding or disbursing any loan based solely on a student’s chosen lender. OFAS employees will, to the best of their abilities, process, award, and distribute all private loan requests equally and without regard to a student borrower’s choice of a lender or banking institution.
  5. OFAS employees shall not, in connection with their employment with the College, accept any gratuity or other consideration that exceeds a de minimus or negligible value, including but not limited to cash, gifts, meals, travel, favors, or other personal benefits, from any of the following:
    1. Any lenders, banks, or other financial institutions;
    2. Any financial aid applicants, their family members or friends, or anyone acting on their behalf;
    3. Any entities doing business with or seeking to do business with the College.

Mandatory Disclosures

  1. Familial Relationships
    1. A “Familial Relationship” is defined as a connection or association between one or more persons based on their consanguinity (i.e. “blood relatives”), legal familial affinity (e.g., spouses, “in-laws,” domestic partners, legal guardians or wards; foster children, parents, and siblings; step- or adoptive children, parents, and siblings); or other particularly close personal relationship (e.g., boyfriend, girlfriend).
    2. OFAS employees and College employees with other Title IV processing departments including but not limited to, admissions, registration, student accounts, and finance; must disclose to the Executive Administrator of Title IV programs their known Familial Relationships with financial aid applicants, student borrowers; or banks, lenders, financial institutions, and any business entities doing business with or seeking to do business with the College. Knowingly failing to report Familial Relationships is a violation of College Policy, as well as 34 CFR 668.15(f)(3), and may result in disciplinary action up to and including immediate termination.
b. Financial Conflicts of Interest
OFAS staff and other Title IV processing departments will disclose to the College any financial involvement or pecuniary interest in, or other potential conflict of interest with, any entity with which the College has a business relationship.


Remaining in “Good Standing”

Per federal regulations, all OFAS employees with access to financial aid systems must, as a condition of their employment, be in “good standing” with the Department of Education at all times. OFAS employees may lose their “good standing” status and become ineligible for continued employment in their positions if they

  1. Default on a student loan,
  2. Have a Pell Grant overpayment, or
  3. Are charged with or convicted of financial aid fraud or other illegal activity related to fraud.

Reporting to the U.S. Department of Education

The College’s executive administrator of Title IV programs will report to the U.S. Department of Education any changes or additions to College locations or changes of control under which a College employee acquires the ability to substantially affect the actions of the College.


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