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.

This Code of Conduct applies to the officers, employees, and agents of the College and prohibits employees of the Office of Financial Aid from receiving gifts from a lender, guaranty agency, or loan servicer.

Additionally, as members of the National Association of Student Financial Aid Administrators (NASFAA), Elmira College financial aid personnel also adhere to the NASFAA Statement of Ethical Principles which contains principles specific to the financial aid profession.

Conflict of Interest

No employee shall have a conflict of interest with respect to any education loan program or other student financial aid program for which the employee has responsibility.

Revenue Sharing

The College shall not enter into any revenue-sharing arrangement with any lender or other vendor working with its Office of Financial Aid. The College shall not accept any fee or other material benefit in exchange for recommending a lender to its students.

Preferred Lender Arrangements

The College does not have a preferred lender arrangement and will not recommend any specific private education loan lender over another.  The College 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 selected. 

Ban on Gifts

No College 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).

Prohibited Consulting/Contract Arrangements

No College 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.

Advisory Board Compensation

A person employed in a financial aid office who serves on an advisory board established by a lender or group of lenders cannot receive anything of value from the lender but can receive reimbursement for reasonable expenses associated with participation.

 

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