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Student Financial Aid Code of Conduct

The ACM Student Financial Aid Office (ACM SFAO) is a member of the National Association of Student Financial Aid Administrators (NASFAA), the Eastern Association of Student Financial Aid Administrators (EASFAA), and the Delaware-District of Columbia-Maryland Association of Student Financial Aid Administrators (DEDCMD ASFAA). 

All of our actions and decisions are bound by NASFAA's Statement of Ethical Principles and Code of Conduct for Institutional Financial Aid Professionals (see below) and regulations developed by the Department of Education of the U.S. Federal Government.  Staff in our office will always act in the best interest of our students and their families.

Currently, ACM participates in the Federal Direct Student Loan Program.  As such, the Department of Education is the lender for all of our Title IV Federal Student Loans.  However, should the Federal Family Education Loan Program (FFELP) be revived, we will adhere to the following code of conduct.

 Established April 2009 -


The Higher Education Opportunity Act of 2008 requires educational institutions participating in a Title IV Loan Program to adhere to a Code of Conduct, which prohibits conflicts of interest between Allegany College of Maryland's (ACM) officers, employees, and agents with any lender, lender servicer, and/or guarantor.  Sections 487 (a) (25) and 487 (e) of the Higher Education Act of 1965, as amended, require the development, administration, and enforcement of a Student Financial Aid Code of Conduct to govern federal student aid programs.  Staff members of the ACM Student Financial Aid Office (SFAO) are bound to act in compliance with the ACM Student Financial Aid Code of Conduct, the Maryland State Code of Conduct, and the Statement of Ethical Principles and Code of Conduct from the National Association of Student Financial Aid Administrators (NASFAA).

Officers, employees, contract employees, trustees, and agents, including alumni associations, booster clubs, foundations, athletic organizations, social, academic, and professional organizations, and other organizations directly or indirectly associated with or authorized by ACM, agree to the provisions of the ACM Student Financial Aid Code of Conduct and will refrain from:

· Revenue Sharing

oNo officer, employee, or agent of ACM shall enter into any revenue-sharing or profit-sharing arrangement with any lender.

· Denial of Borrower's Lender Choice

oThe ACM SFAO shall not deny or delay a Federal Family Education Loan Program (FFELP) borrower his/her choice of a FFELP Lender or Guarantor.  The ACM SFAO shall not assign, through any awarding, certifying, or packaging method, a borrower's loan to a particular lender.

· Prepackaging Private/Alternative Loans

oThe ACM SFAO will not package a private/alternative education loan as part of the student's financial aid award, unless the student has signed the FFELP Waiver Form and continues to agree to the terms and conditions of the private/alternative loan.  The ACM SFAO may suggest that a student borrow under the private/alternative program if the borrower is ineligible for additional funding, has exhausted the limits of the Title IV loan programs, or refuses to complete the Free Application for Federal Student Aid.

· Accepting Gifts, Goods, and/or Services

oNo officer, employee, or agent shall solicit or accept impermissible gifts, goods, and/or services from a FFELP or private/alternative lender, lender servicer, and/or guarantor.   A gift to any family member of the above mentioned is also not permissible.  Gifts, goods, and/or services include:  gratuities, meals, travel, lodging, entertainment (expenses for shows, sporting events, or alcoholic beverages), favors, loans, discounts, hospitality (such as private parties of select training or conference attendees), and in-kind services, such as printing customized consumer information for borrowers with the ACM school logo.  ACM SFAO staff may accept only items of nominal value, certain services, and/or certain materials.  Permissible gifts would include items such as pens, pencils, notepads, sticky-notes, rulers, calculators, small tote bags, and other individual office supply items.  An employee may accept any general items of value from a lender, lender servicer, and/or guarantor provided that the item is also offered to the general public.  ACM SFAO staff may accept informational brochures and can participate in meals, refreshments, and receptions in conjunction with meetings and trainings that contribute to his/her professional development, and conference events open to all attendees. 

· Accepting Philanthropic Contributions

oNo officer, employee, or agent shall accept philanthropic contributions from a lender, lender servicer, and/or guarantor that are related to the educational loans provided by the lender, lender servicer, and/or guarantor or that is made in exchange for any advantage related to the educational loan.  Educational loans here include loans made by ACM under the private/alternative loan program.  ACM will not accept scholarships or grants from a lender or guarantor in exchange for FFELP applications, referrals, a promised loan volume, or placement on the ACM recommended lender list.

· Advisory Board Compensation

oACM employees with responsibility for any financial aid services will not accept anything of value for serving on or otherwise participating as a member of an advisory council or advisory board for a lender, lender affiliate, lender servicer, or guarantor, except that the employee may be reimbursed for reasonable expenses incurred while serving in such capacities.

· Accepting Compensation for Consulting

oNo officer, employee, or agent shall accept from a lender or its affiliate 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 education loan-related services to or on behalf of the lender.

· Lender Staff Assistance

oACM will not request or accept from any lender any assistance with call center staffing or financial aid office staffing.  ACM may accept from a lender professional development training and training materials, educational counseling materials, or staffing services on a short-term, nonrecurring basis during emergencies or disasters.

· Competitive Rates Based on Loan Volume

oThe ACM SFAO shall not request or accept competitive rates on private/alternative loans in exchange for a specified amount of loan activity or in exchange for endorsing the lender's FFELP loans. 

· Lender Affiliated Employment

oACM SFAO staff members shall not accept full time or part time employment with any educational loan lender, lender servicer, and/or guarantor.  Staff members who are approached by these entities shall immediately disclose this information to the SFAO Director.

ACM will not use a Preferred Lender List; however, the SFAO will make use of a Recommended Lender List.  The ACM SFAO may request and accept assistance from lenders and/or guarantors to conduct entrance and exit loan counseling.  ACM SFAO staff shall always be in control of the counseling sessions and will not permit the lender and/or guarantor representative to promote in any way the specific lender's products or services.  ACM will make use of the various lender and/or guarantor's materials and products to aid students in financial literacy. 

ACM is committed to providing the information and resources necessary to help every student achieve educational success and will consider the individual needs of each student. 

The information contained herein has been provided to all ACM officers, employees, and agents affiliated with this college.  In addition, this Student Financial Aid Code of Conduct will be published on the ACM internet site and at least annually, will update the code and inform the officers, employees, and agents of the provisions of this code.  Staff, employees, and agents affiliated with this college who fail to comply with this policy will be subject to all applicable disciplinary actions.

Approved by the Board of Trustees July 20, 2009


   

The State of Maryland's Code of Conduct


The primary goal of the financial aid professional is to help students achieve their educational potential by providing appropriate financial resources. To this end, the ACM Student Financial Aid Office will abide by the College Loan Code of Conduct adopted by the State of Maryland under the direction of Attorney General, Douglas Gansler, on June 13, 2007. In addition, we will adhere to the Statement of Ethical Principles and the Code of Conduct from the National Association of Student Financial Aid Administrators, adopted in April 1999 and amended in May 2007:

College Loan Code of Conduct adopted by the State of Maryland under the direction of Attorney General, Douglas Gansler on June 13, 2007:

1.     Revenue Sharing Restrictions: Colleges may not receive anything of value from any lending institution in exchange for any advantage sought by the lending institution. Lenders cannot pay to get on a school's preferred lender list.

2.     Gift and Trip Restrictions: College employees may not take anything, including trips, of more than nominal value from any lending institution, when such things are offered in connection with the employees' financial aid work.

3.     Advisory Board Compensation Rules: College employees with responsibilities for financial aid work may not receive anything of value for serving on the advisory board of any lending institution.

4.     Preferred Lender Guidelines: College preferred lender lists must be based solely on the best interests of the students who may use the list without regard to financial interests of the college.

5.     Preferred Lender Disclosure: On all preferred lender lists the college must clearly and fully disclose the criteria and process used to select preferred lenders. Students must also be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.

6.     Loan Resale Disclosure: Colleges may not permit a lender to appear on a preferred lender list unless the lender agrees to disclose to the student at the time of the loan any pre-existing agreements to sell the loan to another lender.

7.     Call Center Restrictions: Colleges may not permit employees or agents of lenders to identify themselves to students as employees of the colleges. No employee or agent of a lender may be employed by a college financial aid office.


 

Statement of Ethical Principles and the Code of Conduct from the National Association of Student Financial Aid Administrators, adopted in April 1999, amended in May 2007 and March 2014.


The primary goal of the financial aid professional is to help students achieve their educational goals through financial support and resources. NASFAA members are required to exemplify the highest level of ethical behavior and demonstrate the highest level of professionalism. The following guidelines were last updated by NASFAA's Board of Directors in March 2014.

We, financial aid professionals, declare our commitment to the following Statement of Ethical Principles.

 

Financial aid administrators shall:

Advocate for students 

· Remain aware of issues affecting students and continually advocate for their interests at the institutional, state and federal levels.

· Support federal, state and institutional efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school. 

Manifest the highest level of integrity 

· Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.

· Deal with others honestly and fairly, abiding by our commitments and always acting in a manner that merits the trust and confidence others have placed in us.

· Protect the privacy of individual student financial records.

· Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.

Support student access and success 

· Commit to removing financial barriers for those who want to pursue postsecondary learning and support each student admitted to our institution.

· Without charge, assist students in applying for financial aid funds.

· Provide services and apply principles that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.

· Understand the need for financial education and commit to educate students and families on how to responsibly manage expenses and debt.

Comply with federal and state laws 

· Adhere to all applicable laws and regulations governing federal, state, and institutional financial aid programs.

· Actively participate in ongoing professional development and continuing education programs to ensure ample understanding of statutes, regulations, and best practices governing the financial aid programs.

· Encourage colleagues to participate in the financial aid professional associations available to them at the state, regional, or national level and offer assistance to other aid professionals as needed.

Strive for transparency and clarity  

· Provide our students and parents with the information they need to make good decisions about attending and paying for college.

· Educate students and families through quality information that is consumer-tested when possible. This includes (but is not limited to) transparency and full disclosure on award notices.

· Ensure equity by applying all need-analysis formulas consistently across the institution's full population of student financial aid applicants.

· Inform institutions, students, and parents of any changes in financial aid programs that could affect their student aid eligibility.

Protect the privacy of financial aid applicants 

· Ensure that student and parent private information provided to the financial aid office by financial aid applicants is protected in accordance with all state and federal statutes and regulations, including FERPA and the Higher Education Act, Section 483(a)(3)(E) (20 U.S.C. 1090).

· Protect the information on the FAFSA from inappropriate use by ensuring that this information is only used for the application, award, and administration of aid awarded under Title IV of the Higher Education Act, state aid, or aid awarded by eligible institutions.

 


  Code of Conduct for Institutional Financial Aid Professionals


The following Code of Conduct was last updated by NASFAA's Board of Directors in March 2014. Institutional members of NASFAA will ensure that:

 

1. No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.

a. Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.

b. If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be fully and publically disclosed. Borrowers will not be auto-assigned to any particular lender.

c. A borrower's choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution, even if that lender is not included on the institution's preferred lender list.

d. No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family), or from any entity doing business with or seeking to do business with the institution (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).

2. Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.

3. Institutional award notifications and/or other institutionally provided materials shall include the following:

a. A breakdown of individual components of the institution's Cost of Attendance, designating all potential billable charges.

b. Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.

c. Standard terminology and definitions, using NASFAA's glossary of award letter terms.

d. Renewal requirements for each award.

4. All required consumer information is displayed in a prominent location on the institutional web site(s) and in any printed materials, easily identified and found, and labeled as "Consumer Information."

5. Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.

 


 

 NASFAA MISSION STATEMENT


 

The National Association of Student Financial Aid Administrators (NASFAA) supports the training, diversity, and professional development of financial aid administrators; advocates for public policies and programs that increase student access to and success in postsecondary education; and serves as a forum for communication and collaboration on student financial aid issues.