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Student Financial Aid

Conflict of Interest Policy and Code of Conduct

I. Purpose 

The purpose of this policy is to prohibit conflicts of interest in situations involving student financial aid and to establish standards of conduct for employees with responsibility for student financial aid. 

II. Applicability 

This policy applies to all employees who work in the Student Financial Aid Office and all other University employees who have responsibility related to education loans or other forms of student financial aid. 

III. Definitions 

A. Conflict of Interest 

A conflict of interest exists when an employee's financial interests or other opportunities for personal benefit may compromise, or reasonably appear to compromise, the independent judgment with which the employee performs his/her responsibilities at the University.

B. Employee

Any officer, employee or agent of Clemson University who has any responsibility related to educational loans or other forms of financial aid.  

C. Gift 

Any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than a de minimus amount. The term 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 been incurred. The term “gift” does not include any of the following:  

  1. Standard materials, activities or programs on issues related to a loan, default aversion, default prevention or financial literacy, such as a brochure, a workshop or training. 
  2. Training or informational material furnished to the University as an integral part of a training session that is designed to improve the service of a lender, guarantor or servicer of educational loans to the University if such training contributes to the professional development of the University’s employees. 
  3. Favorable terms, conditions and borrower benefits on an education loan provided to a student employed by the University or an employee who is the parent of a student if such terms, conditions or benefits are comparable to those provided to all students of the University and are not provided because of the student’s or parent’s employment with the University. 
  4. Entrance and exit counseling services provided to borrowers to meet the University’s responsibilities for entrance and exit counseling under federal law, so long as the University’s employees are in control of the counseling, and such counseling does not promote the products or services of any specific lender. 
  5. Philanthropic contributions to the University from a lender, servicer or guarantor of education loans that are unrelated to education loans or any contribution from any lender, guarantor or servicer that is not made in exchange for any advantage related to education loans.
  6. State education grants, scholarships or financial aid funds administered by or on behalf of the State.

D. Opportunity Pool Loan 

A private education loan made by a lender to a student attending the University, or the family of such a student, that involves a payment, directly or indirectly, by the University of points, premiums, additional interest or financial support to such lender for the purpose of such lender extending credit to the student or the family. 

E. Revenue-Sharing Arrangement 

An arrangement between the University and a lender under which

(a) a lender provides or issues a loan to students attending the University or to their families; and 

(b) the University 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 University or its employees. 


IV. Institutional Policy Regarding Education Loans and Student Financial Aid  

A. Revenue-Sharing Arrangements 

The University will not enter into any REVENUE‐SHARING ARRANGEMENTS with any lender. 

B. Interaction With Borrowers 

When participating in the Federal Family Education Loan Program (FFELP), the University will not assign a first‐time borrower’s federal loan, through award packaging or other methods, to a particular lender. The University will not refuse to certify, or delay certification of, any federal loan based on the borrower’s selection of a particular lender or guarantee agency. 

Under no circumstances will the University assign a student’s private student loan to a particular lender, or refuse to certify, or delay certification, of any private loan based on the borrower’s selection of lender or guarantee agency.  

C. Private Loans 

The University will not request, or accept, from any lender any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for the University providing concessions or promises regarding providing the lender with a specified number of federal loans, a specified federal loan volume or a preferred lender arrangement for federal loans.  

D. Co-Branding 

The University will not permit a private educational lender to use the University’s name, emblem, mascot, logo or any other words, pictures or symbols associated with the University to imply endorsement of private loans by the lender. 

E. Staffing Assistance 

The University will not request, or accept, from any lender any assistance with call center staffing or financial aid office staffing. Nothing in this section, however, prevents the University from accepting assistance from a lender related to:  

(a) professional development training for its staff;  

(b) providing educational counseling materials, financial literacy materials or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or  

(c) staffing services on a short‐term, nonrecurring basis to assist the University with financial aid-related functions during emergencies, including State or federally declared natural disasters, federally declared national disasters and other localized disasters and emergencies identified by the Secretary of Education. 

V. Code of Conduct  

A. Conflicts of Interest 

  1. No employee shall have a conflict of interest with respect to any education loan or other student financial aid for which the employee has responsibility. 
  2. No employee may process any transaction related to his/her own personal financial aid or that of a relative. 

B. Gifts 

No employee may accept any gift from a lender, guarantor or servicer of education loans. A gift to a family member of an employee or to any other individual based on that individual’s relationship with the employee shall be considered a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and the employee has reason to believe the gift was given because of the employee’s position at the University. 

Token awards from professional associations (state, regional or national) that recognize professional milestones or extraordinary service to parents and students or scholarships for conference attendance or other professional development opportunities may be accepted.

C. Prohibited Contracting Arrangements 

No employee shall accept from any lender or affiliate of any lender 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 services to a lender or on behalf of a lender relating to education loans. 

D. Advisory Board Compensation 

No employee who serves on an advisory board, commission or group established by a lender, guarantor or group of lenders or guarantors may receive anything of value from the lender, guarantor or group of lenders or guarantors in return for that service except for reimbursement for reasonable expenses incurred by the employee for serving. 

E. Meals 

Meals offered as a part of meetings, conferences or other events may be accepted by employees if all participants in the meeting or event are offered the meal (or if the meals are included as a part of a registration fee). 

VI. Policy Violations 

Violations of this policy may result in disciplinary action in accordance with Human Resource policies.

VII. History 

This policy was approved on December 14, 2009, by the Administrative Council. All affected employees must annually sign an acknowledgement of the policy.