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 College of Southern Maryland’s (CSM) 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 code of conduct to govern federal student aid programs. Staff members of the CSM Student Financial Aid Department (SFAO) are bound to act in compliance with the CSM Code of Conduct, the Maryland State Code of Conduct, and the Statement of Ethical Principles and Code of Conduct from 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 CSM, agree to the provisions of the CSM Code of Conduct and will refrain from
~ No officer, employee, or agent of CSM shall enter into any revenue-sharing or profit-sharing arrangement with any lender.
~ The CSM SFAO shall not deny or delay a Federal Family Education Loan Program (FFELP) borrower his/her choice of a FFELP Lender or Guarantor. The CSM SFAO shall not assign, through any awarding, certifying, or packaging method, a borrower’s loan to a particular lender.
~ The CSM 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 CSM 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.
~ No 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 CSM school logo. CSM SFAO staff may accept only items of nominal value, certain services, and/or certain materials. Permissible gifts would include 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. CSM 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.
~ No 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 CSM under the private/alternative loan program. CSM 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 CSM recommended lender list.
~ CSM 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.
~ No 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.
~ CSM will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. CSM 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.
~ The CSM 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.
~ CSM 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.
CSM will not use a Preferred Lender List; however, the SFAO will make use of a Recommended Lender List. The CSM SFAO may request and accept assistance from lenders and/or guarantors to conduct entrance and exit loan counseling. CSM 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. CSM will make use of the various lender and/or guarantor’s materials and products to aid students in financial literacy.
CSM 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 CSM officers, employees, and agents affiliated with this college. In addition, this code of conduct will be published prominently on the CSM internet site and at least annually, will update the code and inform the officers, employees, and agents of the provisions of this code.