Code of Conduct for Student Loans
Although the University of Michigan-Dearborn’s existing conflict of interest policies would already preclude the conduct prohibited by 34 C.F.R. § 668.14(b)(27),1 for clarity, the University of Michigan-Dearborn hereby establishes, as an addendum to the University of Michigan-Dearborn’s Conflict of Interest and Conflicts of Commitment Staff Implementation Guidelines and the Policy on Faculty Conflicts of Interest and Conflicts of Commitment, this code of conduct in regards to private student loans.
The responsibility for the administration of this code of conduct and its enforcement resides with the UM-Dearborn Provost and UM-Dearborn Vice Provost of Enrollment Management of the University of Michigan-Dearborn.
This code of conduct is applicable to all officers, employees and agents of the University of Michigan-Dearborn and any affiliated organizations with responsibilities (directly or indirectly) with respect to private student loans. UM-Dearborn officers, employees and agents subject to this policy are prohibited from doing any of the following, either on their own behalf or on behalf of the University:
- Participating in a revenue-sharing arrangement with any lender by which the lender pays a fee or provides other material benefits to UM-Dearborn or any officer, employee or agent subject to this policy in exchange for the UM-Dearborn’s recommendation of that lender or its loan products;
- Soliciting or accepting gifts, including reimbursement of expenses or payment of expenses in a manner inconsistent with the requirements set forth in UM-Dearborn’s COI/COC Policies as requiring possible conflicts disclosure, from any lender, guarantor, or servicer that provides private education loans to students, unless the item or payment in question meets the exceptions set forth in 34 C.F.R. § 601.21(c)(2)(iii);
- Accepting from any lender or affiliate any fee, payment, or other financial benefit as compensation for any consulting arrangement or other services contract with or on behalf of a lender of private education loans, except that UM-Dearborn officers, employees, or agents subject to this policy who do not work in the Office of Financial Aid & Scholarships may serve on a lender’s board of directors, provided that they recuse themselves from any board decisions relating to private education loans at UM-Dearborn;
- Directing borrowers to particular lenders or delaying loan certifications;
- Requesting or accepting from any lender any offer of funds to be used for private education loans in exchange for UM-Dearborn’s providing the lender with a specified number of, loan volume of, or preferred lender arrangement for, private education loans
- Requesting or accepting any lender’s assistance with call center or Office of Financial Aid & Scholarships staffing, except that UM-Dearborn may request or accept from any lender (a) professional development training for financial aid administrators, educational counseling or other materials to provide to UM-Dearborn’s student borrowers (provided that such materials indicate the lender’s involvement in preparing or providing them), or (b) short term, nonrecurring staffing assistance with financial aid-related functions during emergencies; and
- Receiving anything of value from any lender, other than reimbursement for reasonable expenses, in exchange for service on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors.
Any employee who is offered any gift or monetary compensation from a lender should contact the Office of Financial Aid for clarification and guidance before responding favorably to that offer.
Should an employee subject to this policy inadvertently accept a gift or other type of monetary compensation from a lender, that employee must immediately notify the Department’s Director or Dean. The amount received, the name of the employee or agent, a brief description of the activity and the dates of the activity for which the expenses were paid or provided must be reported to the Department’s Director or Dean, who must then share that report with the UM-Dearborn Director of Financial Aid & Scholarships. The Director of Financial Aid & Scholarships is responsible for reporting this information annually to the Secretary of the Department of Education.
The UM-Dearborn Director of Financial Aid & Scholarships is responsible for providing annual notification of these requirements to all employees and agents with responsibilities (directly or indirectly) for administration of private education loans. This notification will be done via email in January of each year. In addition, this code of conduct will be published on the websites of UM-Dearborn’s Office of Financial Aid & Scholarships, Human Resources, Enrollment Management, and the Provost’s Office.
- This regulation requires all institutions that participate in the federal Title IV student loan programs to adopt a code of conduct that meets the requirements of 34 C.F.R. § 601.21.
- Because the University of Michigan-Dearborn does not participate in the FFEL Program, the regulation cited applies to the University only as its terms relate to private education loans.
Completed and Approved 7/1/10