Code of Conduct and Conflict of Interest Policy Regarding Student Loans
The Higher Education Opportunity Act (HEOA) of August 14, 2008 requires institutions participating in the Federal Title IV loan programs to develop a code of conduct for the institution’s officers, employees and agents. This is under Public Law 110-315. St. Lawrence University’s officers, employees and agents are required to comply with this code of conduct.
St. Lawrence is committed to providing students and their families with the best information and processing alternatives available regarding student borrowing. In support of this and in an effort to rule out any perceived or actual conflict of interest between St. Lawrence University officers, employees or agents and education loan lenders, St. Lawrence University has adopted the following:
1. St. Lawrence does not participate in any revenue-sharing arrangement with any lender.
2. St. Lawrence University does not permit any officer, employee or agent of the school who is employed in the financial aid office, student financial services office or is otherwise involved in the administration of education loans to accept any gift from any lender, guarantor or servicer.
3. St. Lawrence University does not permit any officer, employee or agent of the school who is employed in the financial aid office, student financial services office or is otherwise involved in the administration of education loans to accept any fee, payment or other financial benefit (including a stock purchase option) from a lender or affiliate of 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.
4. St. Lawrence University does not permit any officer, employee or agent of the school who is employed in the financial aid office or student financial services office or is otherwise involved in the administration of education loans to accept anything of value from a lender, guarantor, or group of lenders and/or guarantors in exchange for service on an advisory board, commission or other group established by such lender, guarantor group of lenders and/or guarantors. St. Lawrence University does not allow for any reimbursement of expenses associated with participation in such boards, commissions or groups by lenders, guarantors, or groups of lenders and/or guarantors.
5. St. Lawrence University does not assign a lender to any first-time borrower through financial aid packaging or any other means.
6. St. Lawrence University recognizes that that a borrower has the right to choose any alternative/private education loan lender from which to borrow to finance his/her education. St. Lawrence University will not refuse to certify or otherwise deny or delay certification of an alternative/private education loan based on the borrower’s selection of a lender and/or guarantor.
7. St. Lawrence University will not request or accept any offer of funds to be used for private education loans to students from any lender in exchange for providing the lender with at specified number or volume of Title IV loans, or a preferred lender arrangement for Title IV loans.
8. St. Lawrence University will not request or accept any assistance with call center or financial aid office staffing.
Beginning with the 2009-2010 academic year, St. Lawrence University will participate in the Federal Direct Stafford Loan program (for qualified students), the Federal Direct PLUS Loan program (for qualified parents of dependent students), and the Federal Direct Grad PLUS loan program (for qualified graduate students). These Direct Loan programs do not use a bank/lender/guarantor process. St. Lawrence works directly with the U.S. Department of Education to offer these loan options. New and continuing students who qualify for Title IV Direct loans will be required to use the Direct Loan process.