Title IV Code of Conduct Requirements

Policy Statement

Adelphi University, as a participant in federal loan programs, is required to have a code of conduct applicable to the institutional personnel with loan responsibilities. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. The Code of Conduct Related to Student Loan Activities is a requirement specific to certain transactions and activities related to financial aid matters. In addition, the law includes requirements related to publication of the code and annual disclosures.

Reason for Policy

HEOA项目参与协议必须由所有参与Title IV财务援助项目(包括学生贷款项目)的机构执行，该协议要求机构的官员、雇员和代理人应遵守一项行为准则。此类守则必须禁止在此类贷款方面与机构的官员、雇员或代理人的责任发生利益冲突，并包括与冲突相关的HEOA规定的条款。该法律进一步规定，该准则应在机构网站的显著位置显示，并每年向所有与此类贷款相关的机构官员、员工和代理人通报该行为准则的规定。卡塔尔世界杯时间表阿德尔菲大学还坚持学生贷款，问责，透明度和执行(石板)法案。

Who Is Governed by this Policy

Staff

Policy

The following Code of Conduct includes requirements specified in the Higher Education Act and applies to offices, employees and agents of Adelphi University:

1. A ban on revenue-sharing arrangements with any lender. This is defined as any arrangement between a school and a lender that results in the lender paying a fee or other benefits, including a share of the profits, to the school, its officer, employees or agents, as a result of the school recommending the lender to its students or families of those students.
2. 禁止金融援助办公室的员工接受任何出借人、担保机构或贷款服务提供商的礼物。This is not limited just to those providers of
   Title IV loans. The statutory language refers to lenders of educational loans thus
   private education loans offered to students at your institution are covered in this
   provision as well. The law does provide for some exceptions related to specific types
   of activities or literature. This includes:
   • Brochures or training material related to default aversion or financial literacy.
   • Food, training or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training.
   • Favorable terms and benefits to the student employed by the institution as long as those same terms are provided to all students at the institution.
   • Entrance and exit counseling as long as the institution’s staff are in control and they do not promote the services of a specific lender.
   • Philanthropic contributions from a lender, GA or service provider unrelated to education loans.
   • State education, grants, scholarships or financial aid funds administered by or on behalf of New York State.
3. A ban on contracting arrangements whereby any employee of the school’s financial aid office may not accept any fee, payment or financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
4. A prohibition against steering borrowers to particular lenders, or delaying loan certifications. This includes assigning any first-time borrowers loan to a particular lender as part of their award packaging or other methods.
5. A prohibition on offers of funds for private loans. Schools may not request or accept such offers. This includes any offer of funds for loans to students at the institution, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans, or inclusion on a preferred lender list.
6. A ban on staffing assistance from a lender. Schools may not request or accept any assistance with call center staffing or financial aid office staffing. However, the law does not prohibit schools from requesting or accepting assistance from a lender related to:
   • Professional development training for financial aid administrators.
   • 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.
   • Staffing services on a short-term, nonrecurring basis to assist the school with financial aid-related functions during emergencies, including New York State-declared or federally declared natural disasters, and other localized disasters and emergencies identified by the secretary.
7. A ban on advisory board compensation. Employees of the institution may not receive anything of value from a lender, guarantor or group in exchange for serving in this capacity. They may, however, accept reimbursement for reasonable expenses incurred while serving in this capacity.

Definitions

Glossary of Terms

Forms

This policy does not have forms associated with it at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Related Information

This policy does not have related information at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Document History

• Last Reviewed Date: September 28, 2017
• Last Revised Date: September 28, 2017
• Policy Origination Date:

Who Approved This Policy

Student Financial Services Officer