The Higher Education Opportunity Act of August 14, 2008 includes provisions that campuses participating in Title IV programs publish a code of conduct which describes prohibited practices related to Title IV loan programs. Prior to this, the CSU coded memorandum “Student Loan Programs – Administrative Safeguards” (AA-2007-12) dated May 3, 2007 has been the standard campuses have followed.
Conflict of Interest
To avoid any conflict of interest with the responsibilities of a CSU employee with respect to student loans, the CSU code of conduct prohibits the following:
- Revenue sharing arrangements with any lender
- The solicitation or acceptance of gifts from a lender, guarantor or servicer by anyone with responsibilities with respect to loans at the institution
- Receipt of any fees, payments or other financial benefits (including a stock purchase option) by anyone with responsibilities with respect to loans from a lender as compensation for any type of consulting arrangement or contract to provide services to a lender or on behalf of a lender relating to education loans
- The assignment of a first-time borrower’s loan to a particular lender or refusing to certify or otherwise delay certification of any loan regardless of the lender or guaranty agency the borrower selects
- The acceptance of any funds to be used for private education loans in exchange for the institution providing concessions to the private lender
- Requesting or accepting assistance with call center staffing or financial aid office staffing from any lender
- Any employee with responsibilities with respect to financial assistance at the institution who serves on an advisory board or commission of a lender or guarantor may not accept anything of value from the lender or guarantor except reimbursement for the reasonable expenses of serving on the board or commission