Introduction
This code of conduct applies to all West Virginia University divisions and to all trustees, employees, officers and agents of the school, including without limitation individuals who are employed in the Financial Aid Office or who otherwise have responsibilities with respect to education loans. West Virginia University is a participant in the Federal Stafford Direct Loan programs. This code reiterates and reflects the school’s continuing commitment to conducting financial aid practices with integrity, free from conflicts of interest, in the interest of students, and in compliance with applicable law [Higher Education Opportunity Act, 20 U.S.C. § 1094 et seq. (“HEOA”)].
Definition
For purpose of this code of conduct, lender means: (a) Any entity that itself or through an affiliate engages in the business of making loans to students, parents or others for purposes of financing higher education expenses or that securitizes such loans; or (b) Any entity, or association of entities, that guarantees or services education loans; or© Any industry, trade or professional association that receives money from any entity described above in subsections (a) and (b).
West Virginia University:
- Does not recommend external lenders to student or their parents.
- Does not refuse to process, based upon the choice of lender, private loan applications.
- Does not enter into any revenue-sharing arrangement with any lender.
- Does not solicit or accept any gift (any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount) from a lender, guarantor, or servicer of education loans. The term gift does not include food, refreshments, training, and informational material as part of an integral training session designed to improve the service of a lender.
- May accept philanthropic contributions from a lender, servicer, or guarantor of educational loans as long as the gift is unrelated to educational loans.
- Prohibits employees of the Financial Aid Office, or any employee who otherwise has responsibilities with respect to educational loans, from entering into any type of consulting arrangement or other contract to provide to a lender service relating to educational loans.
- Prohibits employees of the Financial Aid Office, or any employee who otherwise has responsibilities with respect to educational loans, who serve on an advisory board (or commission or group) relating to educational loans established by a lender or group of lenders from receiving anything of value from the lender or group of lenders in connection with serving on such advisory board (or commission or group). Prohibits external lenders’ employees, representatives, or agents from providing staffing services to the Financial Aid Office. However, assistance is permitted for professional development training; 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 staffing services on a short-term, nonrecurring basis to assist the University 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 of Education.
- Prohibits external lenders’ employees, representatives, or agents from identifying themselves to students of the University or their parents as employees, representatives or agents of the Financial Aid Office.
- Does 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, in exchange for providing the lender with a specified number of loans made, insured, or guaranteed; a specified loan volume of such loans; or a preferred lender for such loans.
- Does not permit any employee who is employed in the Financial Aid Office, or who otherwise has responsibilities with respect to education loans or other student financial aid of the University, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, acceptance of any thing of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.
In addition, West Virginia University Financial Aid Office is committed to:
- Removal of financial barriers for those who wish to pursue postsecondary learning.
- Educating students and families through quality consumer information.
- Respecting the dignity and privacy of students and assuring the confidentiality of students’ records and personal circumstances.
- Ensuring equity by applying all need analysis formulas and packaging policies consistently across the institution’s full population of student financial aid applicants.
- Providing services that do not discriminate against students on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age or economic status.
- Submitting award notifications and denials within a reasonable amount of time from the date of application.
- Ensuring that students have explored all other potential sources of aid before processing private credit based loans.
Final: April 23, 2010