Code of Conduct
As active institutional members of the National Association of Student Financial Aid Professionals (NASFAA), the members of the Office of Student Financial Services at Brandeis University have historically prescribed to the NASFAA Code of Conduct.
The Code is intended to help guide financial aid professionals in carrying out their obligations, particularly with regard to ensuring transparency in the administration of the student financial aid programs, and to avoid the harm that may arise from actual, potential or perceived conflict of interest.
The term “employees” refers to any of the school’s officers, employees and agents who are employed in the Office of Student Financial Services or who have responsibilities with respect to student loans or who have responsibilities with respect to student loans related to Title IV education loans or private loans for educational purposes.
The Code of Conduct establishes the following:
Ban on Revenue-Sharing
Employees shall not enter into any revenue-sharing arrangement with any lender where the lender provides or issues a Title IV loan to the student or student’s family in exchange for the school recommending the lender or the lender’s loan products in exchange for a fee or material benefit including profit or revenue sharing that benefits the school or a school’s employee or agent.
Gift Ban
Employees shall not solicit or accept any gift in the form of a gratuity, favor, discount, entertainment, hospitality, loan, service, transportation, lodging, meals, reimbursement or other item having a monetary value of more than a de minimis (nominal) amount from a lender, guarantor or servicer.
Prohibited Contracting Arrangements
Employees must not accept any fee, payment or other financial benefit (including the opportunity to purchase stock) from a lender as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender.
Prohibit Offers of Funds for Private Loans
The school shall not request or accept funds from any lender for private education loans including funds for an opportunity pool loan to it students in exchange for the school providing promises of a specified loan number or volume or a preferred lender arrangement for educational loans.
Prohibit Assignment of Lender to First-Time Borrower
Employees shall not assign, through award packaging or other methods, a first-time borrower’s loan to a particular lender, other than Direct Loans, or refuse or delay processing of a loan, except in the case of a request for a federal Stafford or PLUS Loan to be processed outside of the Direct Loan process, based on the borrower’s selection of a lender or guarantor.
Ban on Staffing Assistance
Employees shall not accept or request any assistance with call center or financial aid office staffing from any lender except as allowed by law.
Prohibit Receiving of Compensation for Advisory Board Assistance
Employees who serve on an advisory board, commission or group established by a lender, guarantor or group of lenders or guarantors, shall be prohibited from receiving anything of value from the lender, guarantor, group of lenders or guarantors. However, the employee may be reimbursed for reasonable expenses incurred in serving on the advisory board, commission, or group.