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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.

This Policy applies to all employees who work in the Office of Financial Aid and all other University employees who have responsibilities related to education loans or other forms of student financial aid.

A. 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 the University.

B. Gift: Any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than minimum 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:

1. 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.
2. Training or informational material furnished to the University as an integral part of a training session that is 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.
3. 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. (Agents of the University with responsibility for education loans or other student financial aid are also expected to abide by the terms of this Policy.)
4. Entrance and exit counseling services are provided to borrowers to meet the University's responsibilities for entrance and exit counseling under federal law, so long as the University's employees are in control of the counseling, and such counseling does not promote the products or services of any specific lender.
5. 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.
6. State education grants, scholarships, or financial aid funds administered by or on behalf of a State.

C. 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 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 material benefits, including revenue or profit sharing, to the University or its employees.

A. Revenue-Sharing Arrangements
The University will not enter into any revenue-sharing arrangement with any lender.

B. Private Loans
The University will not request or accept from any lender any offer of funds to be used for private education loans to students in exchange for the University providing concessions 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