Standard Administrative Procedure L1.01 Texas Higher Education Fair Lending Practices

Similar documents
CODE OF CONDUCT FOR UNIVERSITY OF NEBRASKA STUDENT FINANCIAL AID WORKERS (January 6, 2010)

Bryant & Stratton College Code of Conduct

UNIVERSITY OF RICHMOND FINANCIAL AID CODE OF CONDUCT. I. Introduction

TITLE IV LOAN SCHOOL CODE OF CONDUCT

I.Definitions A. College Shall mean any community college within the CSCU system, including the Board of Regents.

Financial Aid Code of Conduct

34 CFR 601 Institutional and Lender Requirements Relating to Education Loans

Student Financial Aid Code of Conduct For More Information Contact: Director, Student Services Center Contact Telephone Number: (860)

Student Loan Protection

Connecticut State University System

Institutional Code of Conduct for Education loans Iowa Western Community College June 2016

Institutional Code of Conduct for Educational Loans. The University of Iowa. October 2008

Institutional Code of Conduct for Educational Loans. Mercy/St. Luke s School of Radiologic Technology. July 2017

HF 2690 Model Education Loan Code of Conduct for Covered Postsecondary Institutions

Institutional Code of Conduct for Educational Loans. Des Moines Area Community College

Institutional Code of Conduct for Educational Loans HAWKEYE COMMUNITY COLLEGE

Institutional Code of Conduct for Educational Loans. Iowa Methodist School of Radiologic Technology. January 24, 2009

Common Manual Policy Proposal Transmittal February 29, 2008

DATE ISSUED: 3/28/ of 7 UPDATE 31 DBD(LEGAL)-LJC

WIDENER UNIVERSITY STUDENT FINANCIAL AID CODE OF CONDUCT. I. Prohibition of Certain Remuneration to University Employees

Transylvania University Consumer Information

STUDENT CONSUMER INFORMATION BROCHURE

This document establishes a formal Code of Ethics for the employees of the Metropolitan Washington Airports Authority (the Authority).

Financial Aid: Policies and Procedures for The Juris Doctor Program

Frequently Asked Questions About Company Foundations and Corporate Giving

DATE ISSUED: 7/11/ of 5 LDU DBD(LOCAL)-X

06/28/2018 By: Lydia Ludwig, Controller Next Review: 04/01/ months from last review Crossreferences:

MLGW HUMAN RESOURCES POLICY MANUAL

EXCERPT. Do the Right Thing R1112 P1112

INTERNATIONAL ANTI-CORRUPTION POLICY AND MANUAL

GIFTS, GRATUITIES AND BUSINESS COURTESIES

All University Faculty and Staff

1702 Short-Term Emergency Student Loans Extension of Credit for Sales & Services Loans to Affiliates Employee Loans

Gifts and Gratuities Policy

Proposed Regulatory Language Contextual Format Loans Committee

1 of 2 6/4/2007 9:39 AM

OFFICIAL POLICY. Policy Statement

Disbursement Guidelines

CONFLICT OF INTEREST FOR NON-FACULTY EMPLOYEES

Student Lending 101. A Regulator s Guide to What Students Need to Know

CHARTER SCHOOL GOVERNING BOARD CONFLICT OF INTEREST PROVISIONS

Graduate Award and Billing Guide Office of Student Financial Services

Tennessee State University Board of Trustees. Policy No. 001: Board Code of Ethics and Conduct/Conflicts of Interest Policy

GIFTS TO AN AGENCY FPPC FORM 801-REGULATION QUESTIONS AND ANSWERS

Model Ethics and Conflict-of- Interest Policy for Texas Public Retirement Systems PENSION REVIEW BOARD

Restrictions on Transactions between the IAC Members and the Retirement Systems

CODE OF ETHICS Training for Officials and Employees. Palm Beach County Commission on Ethics

Palm Beach County Code of Ethics Guide for Elected Officials and Advisory Board Members

Anti-Bribery. Statement of Policy

SUMMARY OF ETHICS RULES

Improper Payments. Section. Code of Ethics A. SUMMARY B. APPLICABILITY C. POLICY D. RESPONSIBILITIES E. PROCEDURES F. REFERENCES G.

MAUSER Packaging Solutions Anti-Corruption Policy

CHARITABLE SOLICITATION REGULATION: Frequently Asked Questions. David A. Levitt May 2013

PHILEX PETROLEUM CORPORATION POLICY ON GIFTS, ENTERTAINMENT AND SPONSORED TRAVELS

SUPERIOR-GREENSTONE DISTRICT SCHOOL BOARD

CONFLICT OF INTEREST POLICY

The James Irvine Foundation Conflict of Interest Policy

GUIDE TO PALM BEACH COUNTY CODE OF ETHICS Edition

Huron-Perth Catholic District School Board

Maryland Gift Law. (1) "Gift" means the transfer of anything of economic value, regardless of form, without adequate and lawful consideration.

2:105 Ethics and Gift Ban

SUBJECT: GIFT TYPES, TERMS AND DEFINITIONS

Policy. Name. I. Purpose and Scope:

Illinois Council of School Attorneys. Answers to FAQs Regarding the Gift Ban Provisions of the State Officials and Employee Ethics Act

University of Louisiana System

APPROVED BY BOARD OF TRUSTEES 5/28/09 WITH AMENDMENTS

GOVERNMENT CODE SECTION

CHARITABLE CONTRIBUTIONS AND FUND MANAGEMENT

ORGANIZER FOR TAX EXEMPT ORGANIZATIONS (990)

The analysis regarding securities law in this memorandum has been drafted by Clifford Kirsh of Sutherland Asbill & Brennan LLP.

OPINION NO. 44. (Issued: November 1995) LIMITATIONS ON ACCEPTING GIFTS UNDER THE CODE OF JUDICIAL ETHICS AND CCP 170.9

DEKALB COUNTY GOVERNMENT TRAVEL POLICY (Adopted March 15, 2017)

GIFT, TICKET AND HONORARIA POLICY

DATE ISSUED: 3/21/ of 14 UPDATE 31 CAK(LEGAL)-LJC

SB :06. POLICY CATEGORY: Accounting/Administration. Policy on Gift Acceptance by Corporation

Financial Aid Glossary

Paul Lorenz, MBA Chief Executive Officer, SCVMC. Continuing Medical Education (CME) Standards for Commercial Support

POLICY REGULATING POLITICAL ACTIVITIES AND THE SOLICITATION AND ACCEPTANCE OF GIFTS

SUPERVISION OF TRUSTEES AND FUNDRAISERS FOR CHARITABLE PURPOSES ACT

National Headquarters of Myasthenia Gravis Foundation of America, Inc. Independent Auditor s Report. December 31, 2006

Island Health Guidelines for Commercial Support of Continuing Medical Education/Continuing Professional Development Activities

CONFLICT OF INTEREST HANDBOOK

GLOBAL ANTI-CORRUPTION POLICY

SCOPE This policy applies to all operations of Mack Trucks, Inc., Volvo Group North America, LLC. and their divisions (the Corporation ).

Policy on Gifts & Entertainment

Policy(ies) Superseded: 407 Latest Review/revision: July 2015

Auditors' Opinion 1. Management s Discussion & Analysis Statement of Net Assets 13. Statement of Revenues, Expenses, and Change in Net Assets 14

Wright Medical Group N.V. Anti-Bribery Compliance Policy

ANTI-CORRUPTION POLICY

Board Member Ethics and Conflicts of Interest

Anti-Bribery and Corruption Policy

ANTI-CORRUPTION GENERAL PURPOSE

Guide to Reporting Gifts, Honoraria and Travel Payments. Legal Guidance Provided by CSBA

USTA MIDDLE STATES SECTION. Conflict of Interest and Disclosure Policy - Volunteers

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

OSHER LIFELONG LEARNING INSTITUTE AT GEORGE MASON UNIVERSITY

Cash Disbursement Policy

Omidyar Network Conflict of Interest Policy (Summary)

Introduction to Changes in the Utah Procurement Code Thank you for Attending!

DONOR ADVISED FUND AGREEMENT

Transcription:

Ms. Standard Administrative Procedure 07.02.99.L1.01 Texas Higher Education Fair Lending Practices First Approved: August 30, 2013 Last Revised: August 30, 2013 Next scheduled review: August 30, 2015 Standard Administrative Procedure Statement This standard administrative procedure will help the University set a code of conduct for Financial Aid Professionals as required under the Higher Education Opportunity Act of 2008 and the Texas A&M University System (TAMUS) Policy 07.01 for all financial aid programs adhering to Texas Higher Education Fair Lending practices. Definitions 1. Employee of an institution of higher education: I ncludes any employee, agent, student financial aid contractor, director, officer, or regent of the institution. 2. Gift: M eans any discount, favor, gratuity, inducement, loan, stock, or thing exceeding $20 in value. The term gift includes: 2.1 Any money, service, loan, entertainment, honoraria, hospitality, lodging costs, meal, registration fee, travel expense, discount, forbearance, or promise; 2.2 A gift provided in kind, by purchase of a ticket, through payment in advance, or through reimbursement after expenses have been incurred; 2.3 Any computer hardware for which the recipient pays a below-market price; or 2.4 Any printing costs or services. The term gift does not include: 2.5 A student loan lender s own brochure or promotional literature; 2.6 Training, or informational material furnished to an employee of an institution of higher education as an integral part of a training session, if that training session contributes to the professional development of the employee; or 2.7 Money from a student loan lender that is given to the institution of higher education, outside the O ffice of S tudent F inancial A id, for a philanthropic purpose and not for the purpose of securing a benefit relating to student lending for the student loan lender, including, but not limited to, money for:

2.7.1 Scholarships, grants, work study funds, or similar types of awards that are passed directly onto students; 2.7.2 Any building, room, facility, or equipment for a department other than the department in which the Office of Student Financial Aid is located; 2.7.3 Naming a facility or program in accordance with applicable naming regulations and policies adopted by the institution; or 2.7.4 Programs or operations other than those related to the O ffice of Student F inancial Aid. Money donated as described in this section may not have any direct connection or benefit to any University employee involved in decisions relating to the offering of student loan products and may not be considered by the University in the assessment of a lender in the student loan process. 3. Student loan lender: Any person who is in the business of, independently or through an affiliate: making, brokering, arranging, or accepting applications for student loans; or, any entity or association of entities that guarantees student loans, except for the Texas Guaranteed Student Loan Corporation or, any similarly structured entity. Procedures and Responsibilities All financial aid employees at Texas A&M International University (TAMIU) shall review the Code of Conduct for all Financial Aid Professionals at TAMIU, TAMUS Policy 07.01, Texas Education Code, Section 61.003, the National Association of Student Financial Aid Administrators (NASFAA) Statement of Ethical Principles and the NASFAA Code of Conduct for Institutional Financial Aid Professionals. Financial aid employees will sign a document indicating that they have read, understand, and will comply with the principles contained within. Financial aid employees also participate in Entrance and Exit counseling training sessions to ensure that they are aware of their and the student s rights and responsibilities concerning loans. Code of Conduct Principles A. Prohibition on Revenue Sharing 1. A revenue sharing agreement is defined as any arrangement between an institution and a lender under which, the lender makes Title IV loans to students attending the institution (or to the families of those students), 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 to the institution or to its officers, employees, or agents. 2. Neither Texas A&M International University nor any employee of Texas A&M International University who has responsibilities with respect to financial aid shall enter into any revenuesharing arrangement with any lender. B. Prohibition on Gifts 1. Refer to definition of a gift.

2. No employee of Texas A&M International University s Office of Student Financial Aid (OSFA) (or any family member of such, may solicit or accept any gift from a lender, guarantor, or servicer of education loans. 3. Texas A&M International University is not prohibited from accepting endowment gifts, capital contributions, scholarship funding, or other financial support from a lender, guarantor, or servicer of education loans, so long as the University gives no competitive advantage or preferential treatment to the lender, guarantor, or servicer of education loans related to its education loan activity in exchange for such support. C. Prohibition on Compensation for Consulting, Contracting, or Advising 1. No employee of Texas A&M International University s Office of Student Financial Aid) (OSFA) (or any family member of such, shall accept any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to, or on behalf of, a lender relating to education loans. 2. No employee of Texas A&M International University s Office of Student Financial Aid (OSFA) (or any family member of such, shall accept any fee, payment, or other financial benefit as compensation for serving on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors), except for reimbursement of reasonable expenses incurred by the employee for serving on the board. 3. The Texas A&M International University Office of Student Financial Aid (OSFA) may hold membership in any nonprofit professional association, or may hold individual membership in any nonprofit professional association. 4. Texas A&M International University Office of Student Financial Aid (OSFA) employees are not precluded from attending any educational or training program related to financial aid or higher education loans where no registration fee is charged to any attendee because of a lender, guarantors, or loan servicer s sponsorship or support of the program, and provided that the registration fee is limited to covering the costs associated solely with the education or training component of the program. 5. These prohibitions shall not apply to participation on advisory boards that are unrelated in any way to financial aid or higher education loans. D. Prohibition on Loan Awarding Process 1. The Texas A&M International University, or an employee of the Texas A&M International University Office of Student Financial Aid (OSFA), shall not, for any first-time borrower, assign, through award packaging or other methods, the borrower's loan to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency. 2. The Texas A&M International University, or an employee of the Texas A&M International University Office of Student Financial Aid (OSFA), shall not direct any borrower to a specific lender for the purpose of borrowing an educational loan.

E. Prohibition on Contracting Arrangements for Private Educational Loans 1. Texas A&M International University may not request or accept from any lender any offer of funds to be used for private educational loans to students in exchange for providing concessions or promises to the lender regarding a number of loans, loan volume, or a preferred lender arrangement for private educational loans. 2. This prohibition extends to opportunity pool loans, which are defined as a private education loan made by a lender to a student (or the student s family) that involves a payment by the institution to the lender for extending credit to the student. F. Prohibition of Lending Institutions Providing Staffing Assistance 1. No employee or other agent of a lending institution may staff the Texas A&M International University Office of Student Financial Aid (OSFA) at any time, either in-person or as part of a call center. The University shall ensure that no employee or other representative of a lending institution is ever identified to students or prospective students of the University or their parents as an employee or agent of the University. 2. Representatives of lenders may be allowed to conduct informational sessions, such as exit counseling presentations on loan payment and loan consolidation options, so long as: (a) student attendance is voluntary; (b) a University representative explains that other lenders may provide similar services; (c) the affiliation of the lender representative is disclosed at the start of the presentation; (d) the lender representative does not promote the products or services of any lender, and (e) the University takes reasonable steps to ensure compliance with the requirements of this paragraph. 3. In the event that the University permits a lender to conduct information sessions or exit counseling presentations as explained above, the University must retain control of any presentation offered by Lenders. Control may be evidenced by: (a) a University employee attending such presentation; (b) the University recording or videotaping the presentation; or (c) with respect to an exit counseling session conducted electronically via the internet, the University creating or approving in advance the content of such electronic exit counseling session. 4. Staffing assistance from a lending institution is permitted on a short-term, nonrecurring basis to assist with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, federally declared national disasters, and other localized disasters and emergencies identified by the Secretary. 5. A lender may provide educational counseling materials, financial literacy materials, or debt management materials as long as the materials identify the lender that assisted in preparing the materials. G. In addition, Texas A&M International University Office of Student Financial Aid (OSFA) employees shall: 1. Avoid all conflicts of interest, potential conflicts of interest, and the appearance of conflicts of interest which would result in personal financial gain to the employee. 2. Refrain from knowingly taking any action that is contrary to law, regulation, university policy, or contrary to the best interests of students and their families.

3. Refrain from taking any action or decision for a family member, friend, or business associate that would result in impacting financial aid eligibility, other than running automated processes in which the student is being processed along with many other students. 4. Promote the core values and mission of the Texas A&M International University Office of Student Financial Aid (OSFA). 5. Notify their supervisor, or Director of Financial Aid, of any observed potential conflict of interest by an employee of OSFA. 6. Notify the Director of Financial Aid if any family member, friend, or business associate has been granted the ability to disburse aid by another office of Texas A&M International University. Related Statutes, Policies, Regulations, Rules or Requirements Texas A&M University System (TAMUS) Policy 07.01 Texas Education Code, Section 61.003 Title IV, Higher Education Act of 1965 (Pub. L. No.89-329) Higher Education Opportunity Act of 2008 [HEOA 487(a)(25)] Appendix Code of Conduct for Financial Aid Professional at TAMIU National Association of Student Financial Aid Administrators (NASFAA) Statement of Ethical Principles National Association of Student Financial Aid Administrators (NASFAA) Code of Conduct for Institutional Financial Aid Professionals Contact Office Office of Financial Aid 956-326-2225