Financial Aid Code of Conduct
The Student Loan Sunshine Act
Code of Conduct for Staff in the Office of Admissions and Financial Aid
Background: The Student Loan Sunshine Act (PDF) was passed by the House of Representatives on May 9, 2007. Families should note that staff working in the Office of Admissions and Financial Aid at Our Lady of Holy Cross College have not been implicated in any of the current investigations into practices in the student loan Industry. We:
- do not have any revenue-sharing agreements with lenders
- have not accepted any offers of funds from lenders to be used for private educational loans (also known as "opportunity pools") in exchange for processing federal or private loans for a particular lender
- have not received gifts of stock or other financial compensation from lenders in return for service on a lender's advisory board. No staff members serve on any lender advisory boards
Staff members in the Office of Admissions and Financial Aid have always been bound to act in compliance with the vision outlined in our Mission and the National Association of Student Financial Aid Administrator's Statement of Ethical Practices and Code of Conduct (PDF).
Although the Student Loan Sunshine Act will not become law until matching legislation is passed by the U.S. Senate, staff members in Office of Admissions and Financial Aid will be bound by the following explicit guidance effective May 9, 2007. This guidance is based on information sent from the American Council on Education (PDF). This guidance may be updated after action by the U.S. Senate on this legislation as well as Congressional action on the Reauthorization of the Higher Education Act ("HEA").
- No staff member shall accept any gift worth more than $10 from a representative of a student loan provider. Gifts include meals, travel, lodging, entertainment, and in-kind services (such as printing customized consumer information for borrowers with the school's logo).
- Staff can participate in meals, refreshments, and receptions in conjunction with meetings, training, or conference events open to all attendees.
- On a space available basis, staff will continue the practice of putting all unsolicited marketing materials (such as pens, pads and markers) received from lenders out in the reception area for the use of students and parents. This practice may be amended or discontinued pending further legislative action. A basic "rule of thumb" - anything that can be used by the students is apparently OK. Gifts that are earmarked only for the staff are not.
- Staff members shall not accept any remuneration or expense-reimbursement for serving as a member of a lender's advisory board. Staff may participate on advisory boards that are unrelated in any way to higher education loans.
Staff who knowingly fail to follow these guidelines will be subject to disciplinary action.