Title IV Code of Conduct Requirements

Policy Statement

Adelphi University, as a participant in federal loan programs, is required to have a code of conduct applicable to the institutional personnel with loan responsibilities.  The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. The Code of Conduct Related to Student Loan Activities is a requirement specific to certain transactions and activities related to financial aid matters. In addition, the law includes requirements related to publication of the code and annual disclosures.

Reason for Policy

The HEOA program participation agreement, which must be executed by all institutions participating in Title IV financial aid programs including student loan programs, requires a code of conduct with which the institution’s officers, employees, and agents shall comply. Such code must prohibit a conflict of interest with the responsibilities of an officer, employee, or agent of an institution with respect to such loans, and include the provisions set forth in the HEOA related to conflicts. The law further specifies that the code shall be displayed prominently on the institution’s website and that all institutional officers, employees and agents with responsibilities related to such loans be annually informed of the provisions of the code of conduct. Adelphi University also adheres to the Student Lending, Accountability, Transparency and Enforcement (SLATE) Act.

Who Is Governed by this Policy

Staff

Policy

The following Code of Conduct includes requirements specified in the Higher Education Act and applies to offices, employees and agents of Adelphi University:

1. A ban on revenue-sharing arrangements with any lender. This is defined as any arrangement between a school and a lender that results in the lender paying a fee or other benefits, including a share of the profits, to the school, its officer, employees or agents, as a result of the school recommending the lender to its students or families of those students.
2. A ban on employees of the financial aid office receiving gifts from any lender, guaranty agency or loan service provider. This is not limited just to those providers of
   Title IV loans. The statutory language refers to lenders of educational loans thus
   private education loans offered to students at your institution are covered in this
   provision as well. The law does provide for some exceptions related to specific types
   of activities or literature. This includes:
   • Brochures or training material related to default aversion or financial literacy.
   • Food, training or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training.
   • Favorable terms and benefits to the student employed by the institution as long as those same terms are provided to all students at the institution.
   • Entrance and exit counseling as long as the institution’s staff are in control and they do not promote the services of a specific lender.
   • Philanthropic contributions from a lender, GA or service provider unrelated to education loans.
   • State education, grants, scholarships or financial aid funds administered by or on behalf of New York State.
3. A ban on contracting arrangements whereby any employee of the school’s financial aid office may not accept any fee, payment or 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.
4. A prohibition against steering borrowers to particular lenders, or delaying loan certifications. This includes assigning any first-time borrowers loan to a particular lender as part of their award packaging or other methods.
5. A prohibition on offers of funds for private loans. Schools may not request or accept such offers. This includes any offer of funds for loans to students at the institution, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans, or inclusion on a preferred lender list.
6. A ban on staffing assistance from a lender. Schools may not request or accept any assistance with call center staffing or financial aid office staffing. However, the law does not prohibit schools from requesting or accepting assistance from a lender related to:
   • Professional development training for financial aid administrators.
   • 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.
   • Staffing services on a short-term, nonrecurring basis to assist the school with financial aid-related functions during emergencies, including New York State-declared or federally declared natural disasters, and other localized disasters and emergencies identified by the secretary.
7. A ban on advisory board compensation. Employees of the institution may not receive anything of value from a lender, guarantor or group in exchange for serving in this capacity. They may, however, accept reimbursement for reasonable expenses incurred while serving in this capacity.

Definitions

Glossary of Terms

Forms

This policy does not have forms associated with it at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Related Information

This policy does not have related information at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Document History

• Last Reviewed Date: August 01, 2023
• Last Revised Date:August 01, 2023
• Policy Origination Date: Unknown

Who Approved This Policy

Kristen Capezza, Vice President of Enrollment Management and University Communications