Financial Aid

Conflict of Interest Policy

Mount Saint Mary College
Conflict of Interest Policy and Code of Conduct for Financial Aid Professionals

Purpose

The purpose of this policy is to prohibit conflicts of interest in situations involving student financial aid and to establish standards of conduct for employees with responsibility for student financial aid.

Applicability

This policy applies to all employees who work in the Financial Aid Office and all other College employees who have responsibilities related to educational loans or other forms of student financial aid.

Definitions

  • Conflict of Interest: A conflict of interest exists when an employee’s financial interests or other opportunities for financial gain compromise or appear to compromise the independence of judgment with which the employee performs his or her duties at the College.
  • Gift: Any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than a de minimus amount. The term includes a gift of services, transportation, lodging, or meals, whenever provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.
  • Revenue Sharing Arrangement: An arrangement between the College and a lender under which a lender provides or issues a loan to a student (or their family) attending the College and the College recommends the lender or the loan products and in exchange, the lender pays a fee or provides other material benefits including revenue or profit sharing to the College or its employees.

College Policy Regarding Educational Loans and Student Financial Aid

  • As required by Federal Regulations, the College participates in the Federal Direct Loan Program.
  • Revenue Sharing Arrangements: The College will not enter into revenue sharing arrangements with any lender.
  • Interaction with the Borrower: Under no circumstances will the College assign a student’s private student loan to a particular lender or refuse to certify or delay certification of any private loan based on the borrower’s selection of a lender or guaranty agency.

CODE OF CONDUCT

Conflicts of Interest

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

No employee may process any transaction related to his/her own personal financial aid eligibility or that of a relative.

Gifts: No employee may accept any gift from a financial aid recipient, his or her family member, a lender, guarantor, or servicer of educational loans. A gift to a family member of any employee or to any other individual based on that individual’s relationship with the employee shall be considered a gift to the employee if the gift is given with the knowledge and the acquiescence of the employee and the employee has reason to believe the gift was given because of the employee’s position at the College.

Prohibited Contracting Arrangements: No employee shall accept from any lender, service provider or affiliate of any lender or service provider any fee, payment or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services.

Advisory Board Compensation: No employee who serves on an advisory board, commission or group established by a lender, guarantor, or group or lenders or guarantors may receive anything of value from the lender, guarantor or group of lenders or guarantors in exchange for providing that service.