Policy Library

670 Conflict of Interest Policy/Code of Conduct Financial Aid Professionals

Authority: Approved by the Board of Trustees
Last updated on: June 11, 2020

670.1 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.

670.2 Applicability

This Policy applies to all employees who work in the Office of Student Financial Aid and all other University employees who have responsibilities related to education loans or other forms of student financial aid. Agents of the University with responsibility for education loans or other student financial aid are also expected to abide by terms of this Policy.

670.3 Definitions

670.3.1 Conflict of Interest: A conflict of interest exists when an employee’s financial interests or other opportunities for personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the employee performs his/her responsibilities at Indiana State.

670.3.2 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, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred. The term “gift” does not include any of the following:

a. Standard materials, activities, or programs on issues related to a loan default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.

b. Training or informational material furnished to Indiana State as an integral part of a training session designed to improve the service of a lender, guarantor, or servicer of educational loans to the University, if such training contributes to the professional development of the University’s employees.

c. Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the University or an employee who is the parent of a student if such terms, conditions, or benefits are comparable to those provided to all students of the University and are not provided because of the student’s or parent’s employment with the University.

d. Entrance and exit counseling services provided to borrowers to meet the University’s responsibilities for entrance and exit counseling under federal law, so long as the ISU employees are in control of the counseling, and such counseling does not promote the products or services of any specific lender.

e. Philanthropic contributions to an institution from a lender, servicer, or guarantor of education loans that are unrelated to education loans or any contribution from any lender, guarantor, or servicer that is not made in exchange for any advantage related to education loans.

f. State education grants, scholarships, or financial aid funds administered by or on behalf of a State.

670.3.3 Opportunity pool loan: A private education loan made by a lender to a student attending the University or the family member of such a student that involves a payment, directly, or indirectly, by the University of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family.

670.3.4 Revenue-sharing arrangement: An arrangement between the University and a lender under which (a) a lender provides or issues a loan to students attending the University and a lender or to their families; and (b) the University recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other materials, benefits, including revenue or profit sharing, to the University or its employees.

670.4 Institutional Policy Regarding Education Loans and Student Financial Aid

670.4.1 Revenue Sharing Arrangements. Indiana State University will not enter into any revenue-sharing arrangements with any lender.

670.4.2 Interaction with Borrowers.

670.4.2.1 No Particular Lender for FFELP. When participating in the Federal Family Education Loan Program (FFELP), the University will not assign a first-time borrower’s federal loan, through award packaging or other methods, to a particular lender. Indiana State will not refuse to certify, or delay certification of, any federal loan based on the borrower’s selection or a particular lender or guaranty agency.

670.4.2.2 Federal Direct Loan Program. When participating in the Federal Direct Loan Program, Indiana State will assign a first-time borrower’s federal loan to the Federal Government as the lender.

670.4.2.3 No Particular Lender for Private Student Loan. Under no circumstances will the University assign a student’s private student loan to a particular lender, or refuse to certify or delay certification of any private loan, based upon the borrower’s selection of lender or guaranty agency.

670.4.3 Private Loans. Indiana State will not request or accept from any lender any offer of funds to be used for private education loans, as defined in the federal Truth in Lending Act 15 USCA § 1631 et seq., including funds for an opportunity pool loan, to students in exchange for the University providing concession or promises regarding providing the lender with (i) a specified number of federal loans; (ii) a specified federal loan volume; or (iii) a preferred lender arrangement for federal loans.

670.4.4 Co-Branding. Indiana State will not permit a private educational lender as defined in the federal Truth in Lending Act 15 USCA § 1631 et seq., to use the University’s name, emblem, mascot, logo, or any other words, pictures, or symbols associated with the University to imply endorsement of private educational loans by that lender.

670.4.5 Staffing Assistance. The University will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Nothing in this section, however prevents the University from accepting assistance from a lender related to (i) professional development training for its staff; (ii) providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or (iii) staffing services on a short-term non-recurring basis to assist the University with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, federally declared national disasters, and other localized disasters and emergencies identified by the Secretary of Education.

670.5 Code of Conduct

670.5.1 Conflict of Interest. No employee shall have a conflict of interest with respect to any education loan or other student financial aid for which the employee has responsibility. No employee may process any transaction related to his/her own person financial aid eligibility or that of a relative. For the purposes of this policy, a “relative” is defined as an individual with whom an employee has a relationship by blood, marriage, adoption, domestic partnership, or other personal relationships in which objectivity might be impaired.

670.5.2 Gifts. No employee may accept any gift from a lender, guarantor, or servicer of education loans. A gift to a family member of an employee or to any other individual based on that individual's relationship to the employee shall be considered a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and the employees has reason to believe the gift was given because of the employees position at the University.

670.5.2.1 Token awards. Token awards from professional associations (state, regional, or national) which recognize professional milestones or extraordinary service to parents and students, or scholarships for conference attendance or other professional development opportunities, may be accepted.

670.5.3 Prohibited Contracting Agreements. No employee shall accept from any lender or affiliate of any lender any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting or other contract to provide services to a lender or on behalf of the lender relating to education loans.

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

670.5.5 Reimbursement of Expenses. Expenses incurred while attending professional association meetings, conferences, or in connection with service on an advisory board, commission, or group described in Section 670.5.4 of this policy must be paid by the University. Entertainment expenses such as concert or sports tickets or greens fees may not be accepted. Employees are expected to personally pay for such expenses or request reimbursement from ISU in accordance with University policy.

670.5.6 Meals. Employees may occasionally need to share meals with employees of lenders, guaranty agencies, the State of Indiana, or other colleges or universities in the course of business. Meals offered as part of meetings, conferences, or other events may be accepted if all participants in the meeting or event are offered meals or if the meals are included as a part of a registration fee.

670.6 Policy Violations

Violations of this Policy may result in disciplinary action, up to, and including dismissal.

670.7 History

This policy was created in April, 2009, in order to comply with HEOA Act of 2008.

Related Information

Policy Administrator:
Office of the General Counsel
Policy Contact:
Office of the General Counsel
Parsons Hall 223
(812) 237-4141
Procedures and Standards:
Policy History:
This policy was created in April, 2009, in order to comply with HEOA Act of 2008. Policy 670 was approved by the ISU Board of Trustees on May 9, 2009. On June 11, 2020, a minor change was made to Section 570.5.2 Gifts.