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