Code of Conduct
The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid personnel. In compliance with this requirement, the University of Notre Dame has created the following code of conduct based on the HEOA of 2008.
Other College employees, officers, and agents with responsibilities in respect to education loans also have to comply with this policy.
Conflict of Interest
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.
Ban on Revenue-Sharing Arrangements
The University shall not enter into any revenue-sharing arrangement with any lender or other vendor working with any of its financial aid offices. The University shall not accept any fee or other material benefit in exchange for recommending a lender to its students.
Gift Ban
No University officer or employee with financial aid responsibilities shall solicit or accept a gift (e.g. , a gift of services, transportation, lodging, or meals, provided by purchase of a ticket, payment in advance, or reimbursement) having a monetary value of more than a de minimus amount from a lender, guarantor, or servicer of education loans.
Contracting Arrangements Prohibited
No University officer or employee with financial aid responsibilities shall accept from any lender or lender affiliate any payment or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender.
Interaction with Borrowers
The University shall not automatically assign a particular lender to any borrower, and shall not refuse to certify or delay certification of any loan based on the lender or guarantee agency selected.
Prohibition on Offers of Funds for Private Loans
The University shall not request or accept from any lender an offer of funds to be used for private education loans in exchange for the University providing the lender with a specified number or volume of federal loans made or in exchange for placement on a preferred lender list.
Co-branding
The University prohibits any private educational lender from using the University’s name, emblem and logo as well as any words, pictures, or symbols associated with the University to imply endorsement of private education loans by that lender.
Ban on Staffing Assistance
The University shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Lenders, however, may provide professional development training to financial aid administrators, educational advising materials to borrowers, or assistance in state or federally-declared natural disasters.
Advisory Board Assistance
All employees with financial aid responsibilities shall be prohibited from receiving anything of value from a lender or guarantor in return for service on its advisory board. Reimbursement for reasonable expenses incurred in connection with such service, however, is permitted.