Code of Conduct
Georgia State University participates in the William D. Ford Federal Direct Loan Program, which includes the Direct Subsidized and Direct Unsubsidized Student Loans, the Direct Graduate PLUS Loans, and the Direct Parent PLUS Loans. The University also processes private loans for students on an as needed basis. To comply with the 2008 Higher Education Opportunity Act (the “Act”) the University adopts the following Code of Conduct to provide guidance to University employees in ensuring the integrity of the student aid process and in ensuring ethical conduct of University employees in regard to student loan practices. This Code of Conduct is applicable to all University employees and agents, and specifically, the University’s Office of Student Financial Aid, the Office of Student Accounts, and any other applicable University student financial aid offices.
- Revenue Sharing
The term “revenue-sharing arrangement” means an arrangement between an institution and a lender that – (i) a lender provides or issues a loan that is made, insured, or guaranteed to students under the Act attending the institution or to the families of such students; and (ii) the institution 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 institution, an officer or employee of the institution.
The university and its employees will not enter into any type of revenue-sharing arrangement with any lender, guarantor or servicer. All loans are processed without regard to lender or mode of transmission (i.e., electronic or paper). The University will neither recommend a private loan lender nor accept material benefits including revenue or profit sharing to the University, an officer, or an employee of the University or an agent.
Employees of the Office of Student Financial Aid and the Office of Student Accounts are prohibited from soliciting or accepting any gift from a lender, guarantor, or servicer of education loans.
a. Gifts include any gratuity, favor, discount, entertainment, hospitality, loan or other similar item having a monetary value of more than a de minimus amount. This 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 incurred. However, gifts do not include those specific exemption set forth in the Act (20 U.S.C. Section 1094(e)(2)(B)(ii)).
b. Gifts to family members of a University employee are considered to be a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and there is reason to believe the gift was given because of the official position of that employee.
- Contracting Arrangements
Employees of the Offices of Student Financial Aid and Office of Student Accounts shall not accept from any lender, or affiliate of any lender, any fee, payment, or other financial benefit (including opportunity to purchase stock) as compensation for any consulting arrangement or other contract to provide services to a lender, or on behalf of a lender, relating to education loans.
- Preferred Lender Status
University participates in the William D. Ford Federal Direct Loan Program, which provides student and parent loans through the United States Department of Education. Lenders in the private student loan industry will not be given a preferred status. University will not produce a preferred lender list that gives any lender an advantage in securing business from University students. Any University preferred lender list will clearly and fully disclose the criteria and process used by the University to select preferred lenders. Further, students will be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.
- Interaction with Borrowers
University will not assign a borrower’s private student loan to a particular lender; all decisions will be made by the borrower in his/her independent review of borrower benefits and lender services. Further, university will not refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
- Opportunity Pool Loan
University will not request or accept from any lender any offer of funds to be used for private education loans (defined in section 140 of the Truth in Lending Act) including funds for an opportunity pool loan in exchange for University providing concessions or promises regarding providing the lender with a specified number of loans made, insured or guaranteed; a specified loan volume of such loans; or a preferred lender arrangement for such loans.
- Staffing Assistance
University will not request or accept from any lender, guarantor, or servicer of student loans any assistance with call center staffing or financial aid office staffing. The University will also prohibit employees, representatives, or agents of any lender, guarantor, or servicer of student’s loans from identifying themselves to students of the University or their parents as employees, representatives, or agents of the University.
- Advisory Board Compensation
Employees of the Office of Student Financial Aid and Office of Student Accounts who serve on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, are prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group. Any employee who serves on such an advisory board, commission or group described above shall recuse himself or herself from any discussions regarding the University’s financial aid operations.
- Use of Mascot, Logo, or Name by Lenders
No lender, guarantor, or group of lenders or guarantors, shall be permitted to use the name, emblem, mascot, or logo of Georgia State University, or other words, pictures, or symbols readily identified with or marks of Georgia State University in the marketing of private educational loans to the students attending Georgia State University in any way that implies that Georgia State University endorses the private educational loans offered by the lender, guarantor, or group of lenders or guarantors.
In addition to the above, employees of the Office of Student Financial Aid and the Office of Student Accounts shall comply with all other applicable federal, state, and local laws and regulations, as well as the University’s policies and procedures, including its Conflict of Interest Policy. Notwithstanding the above, nothing in this Code of Conduct shall be construed to conflict with any provisions of the Official Code of Georgia regarding ethical conduct and avoidance of conflicts of interest by State employees.
This Georgia State University Code of Conduct is available on the University’s Office of Student Financial Aid web site. Copies are also available from the Office of Student Financial Aid.