Code of Conduct for Financial Aid Professionals

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The Higher Education Opportunity Act of 2008 (HEOA) requires institutions of higher education to establish and follow a Code of Conduct with respect to student loans that prohibits conflicts of interest for any financial aid professional [HEOA § 487(a)(25)]. In accordance with this requirement, the Financial Aid Office at Trinity Christian College has issued the following conflict of interest policy and code of conduct.

Any Trinity Christian College officer, employee, or agent who has responsibilities with respect to student educational loans is required to comply with this code of conduct as outlined below.

Financial aid professionals should not:

  • Enter into any revenue-sharing arrangement with any lender.
  • Take any action he or she believes is contrary to law, regulation, or the best interests of the students and parents he or she serves.
  • Solicit or accept from a lender, guarantor, or servicer of education loans:
    • any gift, including gratuity, favor, discount, entertainment, hospitality, loan, or other items having a monetary value of more than a nominal amount;
    • any payment or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender;
    • an offer of funds to be used for private education loans or opportunity pool loans in exchange for providing the lender with a specified number of loans, a specified loan volume, or placement on a preferred lender list;
    • any assistance with call center staffing or financial aid staffing. Lenders, however, may provide professional development training to financial aid administrators, educational advising materials to borrowers, or assistance in state or federally declared natural disasters;
    • anything of value in return for serving on an advisory board. Reimbursement for reasonable expenses incurred in connection with such service, however, is permitted.
  • Automatically assign a particular lender to any borrower, and shall not refuse to certify or delay certification of any loan based on the lender or guarantee agency selected.
  • Identify employees, representatives, or agents of external lenders to students or their parents as employees, representatives, or agents of the financial aid office.

Financial aid professionals should:

  • Ensure that the information he or she provides is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
  • Be objective in making decisions and advising his or her institution regarding relationships with any entity involved in any aspect of student financial aid.
  • Maintain exemplary standards of professional conduct in all aspects of carrying out his or her responsibilities, specifically including all dealings with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized, or regulated activity.