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These have been adopted from NASFAA and Texas Fair Lending Practices.

Code of Conduct

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.
   • 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.
   • 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 publicly disclosed. Borrowers will not be auto-assigned to any particular lender.
   • 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.
   • 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 financial aid offers and/or other institutionally provided materials shall include the following:
   • Breakdown of estimated individual Cost of Attendance components, including which are direct (billed by the institution) costs vs. indirect (not billed by the institution) costs
   • Clear identification and proper grouping of each type of aid offered indicating whether the aid is a grant/scholarship, loan, or work program
   • Estimated net price
   • Standard terminology and definitions, using NASFAA’s glossary of terms
   • Renewal requirements for each aid type being offered as well as next steps and financial aid office contact information
4. All required consumer information is displayed in a prominent location on the institutional website(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.

Statement of Ethical Principles

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.
• Strive to ensure that cost of attendance components are developed using resources that represent realistic expenses.

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.

Texas Higher Education Fair Lending Practices

Revised November 15, 2018 (MO -2018), Next Scheduled Review: November 15, 2023

Policy Summary

The president of each university (academic institution) in The University of Texas System will adopt guidelines implementing this policy. This policy sets out operational and conflict of interest standards to be observed and to aid in establishing a heightened awareness of the potential for conflicts of interest in the conduct of student financial aid programs.

Policy

PROHIBITIONS

1.1 Prohibition against solicitation or acceptance of gifts by the institution and the institution’s employees.

1.1.1 The institution will not, directly or indirectly, solicit or accept any gift from or on behalf of a student loan lender.

1.1.2 An employee of the institution will not, on the employee’s own behalf or on behalf of another person, directly or indirectly, solicit or accept any gift from or on behalf of a student loan lender. An employee will promptly report to the institution president any instance of a student loan lender attempting to offer or provide a gift to the employee.

1.2 Prohibition against revenue sharing with lender. The institution will not engage in revenue sharing with a student loan lender.

1.3 Prohibition against acceptance of remuneration by institution employee for service on lender board.

1.3.1 An employee of the institution will not accept any remuneration or reimbursement of expenses from a student loan lender for serving as a member of, or otherwise participating in, an advisory board, or board of directors or any other board or management council of a student loan lender.

1.3.2 An employee of the institution must obtain written authority from the institution president to serve as a member or otherwise participate in an advisory board, board of directors or any other board or management council of a student loan lender before becoming such a member or participant.

1.4 Prohibition against misleading identification of lender employees and representatives. The institution must not identify an employee, representative, or agent of a student loan lender to borrowers or prospective borrowers as an employee, representative, or agent of the institution, nor will the institution, subject to its good faith efforts, authorize an employee, representative or agent of a student loan lender to represent, explicitly or implicitly, that he/she is an employee, representative or agent of the institution.

1.5 Prohibition against high risk student loan agreements. The institution must not enter into a high risk student loan agreement with a student loan lender under which the institution provides concessions or promises to the student loan lender that may prejudice borrowers or prospective borrowers.

1.6 Prohibition against directing potential borrowers to certain electronic loan agreements. The institution will not direct in any manner a potential borrower who attends or has indicated an intent to attend the institution to an electronic master promissory note or other loan agreement that does not allow the borrower to enter the lender code or name for any student loan lender offering the relevant loan. This provision does not prohibit the institution from directing a potential borrower who has represented that he/she wishes to engage a particular lender to that lender’s electronic loan agreements.

1.7 Disclosure of financing options required. The institution will make available to a borrower, a borrower’s parents, or a prospective borrower clear and conspicuous disclosure of information relating to available financing options under Title IV, Higher Education Act of 1965 (Pub. L. No. 89-329), including information on any terms and conditions of available loans under that title that are more favorable to the borrower than terms available through “preferred lenders.” The institution’s conspicuous posting of this information on a website available to borrowers, borrowers’ parents and prospective borrowers will satisfy its duties under this section.

1.8 Requirements relating to lender lists

1.8.2 If the institution provides or makes available to students or prospective students of the institution a lender list, it must ensure that the list: (a) is the product of a collaborative, objective process which recognizes the students’ best interest as the overriding consideration; (b) discloses clearly and conspicuously to borrowers and prospective borrowers the process and defined set of objective criteria by which the institution has selected student loan lenders for inclusion in the list, including the methods and criteria used to choose the lenders and the relative importance of the criteria; (c) states, clearly and conspicuously to borrowers and prospective borrowers, that a borrower has the right and ability to select the student loan lender of the borrower’s choice, is not required to use any of the lenders on the list, and will not be penalized for selecting a lender that is not on the list; and (d) is reviewed and updated at least annually.

1.8.3 The institution’s decision to include a student loan lender on a lender list and the institution’s decision regarding where on the lender list the student loan lender’s name appears must be determined solely by consideration of the best interests of the borrowers or prospective borrowers who may use the list, without regard to the pecuniary interests of the institution. Should the institution maintain a preferred lender list, unless the order of the lenders in the list is a rank order as determined by the process described in Section 1.8.2, the institution will periodically sort the list so entities on the list are shifted in their position. If the order of the lenders on the list is not a rank order, then the institution will clearly and conspicuously disclose that although each lender has been chosen based on the objective criteria described in the Texas Higher Education Fair Lending Practices, no lender within the list is preferred over another.

1.8.4 The institution may include a student loan lender on the institution’s lender list only if the lender provides assurance to the institution and to borrowers of the lender that the advertised benefits on loan repayment will continue to benefit the borrowers regardless of whether the lender’s loans are sold.

1.8.5 Before including a student loan lender on a lender list, the institution will make a reasonable inquiry regarding whether the lender has an agreement to sell its loans to another unaffiliated lender. If, after making reasonable inquiry, the institution has knowledge of such an agreement, the institution may include the lender on the institution’s preferred lender list only if the existence and general nature of the agreement are disclosed clearly and conspicuously on the preferred lender list.

1.8.6 Before compiling a lender list, the institution will make a reasonable inquiry as to the availability of zero-interest loan providers and non-profit loan providers.

1.8.7 A student loan lender may not be placed on any institution lender list or be provided favored placement on any institution lender list for a particular type of 07.02 Texas Higher Education Fair Lending Practices Page 4 of 4 loan in exchange for benefits provided to the institution or to students of the institution in connection with a different type of loan.

1.8.8 The institution will not place a student loan lender on a lender list for a period of at least one year if the student loan lender has violated the Texas Higher Education Fair Lending Practices.

1.8.9 The institution must ensure that the requirements of 34 CFR Part 601, Subpart B are met with creating and distributing any lender list.

1.9 Prohibition against stock ownership. A person employed in the financial aid office of the institution will not own stock or hold another ownership interest in a student loan lender, other than through ownership of shares in a publicly traded mutual fund or similar investment vehicle in which the person does not exercise any discretion regarding the investment of the assets of the fund or other investment vehicle.

REQUIREMENT

On a yearly basis, every employee of the financial aid office of the institution will receive training concerning Texas Higher Education Fair Lending Practices and Texas ethics laws relating to state employment.

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