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Office of Financial Aid & Scholarships

Code of Conduct

Introduction

RIT's Code of Conduct for Financial Aid Professionals ("Code") seeks to establish standards of conduct for its employees responsible for student financial aid and to prohibit conflicts of interest in situations involving student financial aid.  This Code applies to all RIT officers, employees, and agents who work in the Office of Financial Aid & Scholarships or who otherwise have responsibilities related to student financial aid (collectively referred to as "Financial Aid Professional").  In addition to the standards set forth within RIT's Individual Conflicts of Interest and Commitment Policy and RIT's Compliance Policy and Code of Ethical Conduct, a Financial Aid Professional shall review and comply with this Code to help ensure RIT retains high ethical standards. 

General Provisions

Conflicts of Interest

No Financial Aid Professional shall have a conflict of interest with respect to any student financial aid for which the Financial Aid Professional has any responsibility.   For the purpose of this Code, a conflict of interest exists when one's personal, professional, commercial, or financial interest may compromise, or reasonably appear to compromise, the independence of judgment with which one performs his/her responsibilities at the Institute.  If a Financial Aid Professional suspects that a conflict of interest exists or may exist, he/she shall follow the steps for disclosing and managing individual conflicts of interest or commitments as set forth within RIT's Procedures for Implementation of the Individual Conflict of Interest and Commitment Policy.

Revenue-Sharing Arrangements

No Financial Aid Professional or agent acting on behalf of the Institute shall enter into a revenue-sharing arrangement with any lender.  A revenue sharing arrangement refers to any arrangement between the Institute and a lender where, in exchange for a fee or other material benefits, such as revenue or profit sharing, a lender provides or issues a loan to students attending the Institute or to their families and the Institute recommends the lender or the loan products of the lender.

Gifts

No Financial Aid Professional shall accept any gift from a lender, guarantor, or servicer of education loans. A gift to a family member of a Financial Aid Professional shall be considered a gift to the Financial Aid Professional if the gift is given with the knowledge and acquiescence of the Financial Aid Professional and the Financial Aid Professional has reason to believe the gift was given because of the Financial Aid Professional's position at the Institute.

For the purpose of this policy, gift refers to any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.

Contracting Arrangements

No Financial Aid Professional shall accept from any lender or affiliate of any lender any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.

Interaction with Borrowers

No Financial Aid Professional acting on behalf of the Institute shall assign a first-time borrower's loan, through award packaging or other methods, to a particular lender.  No Financial Aid Professional acting on behalf of the Institute shall refuse to certify, or delay certification of, any loan based on the borrower's selection or a particular lender or guaranty agency.

Private Loans

No Financial Aid Professional or agent acting on behalf of the Institute shall request or accept from any lender any offer of funds to be used for private student education loans in exchange for the Institute providing concessions or promises to the lender that involves a payment by the Institute of points, premiums, additional interest, or financial support to the lender for extending credit to the student or the family.

Staffing Assistance

No Financial Aid Professional or agent of the Institute shall request or accept from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training, educational counseling materials (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, nonrecurring basis during emergencies or disasters. 

Advisory Board Compensation

No Financial Aid Professional who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors may receive anything of value from the lender, guarantor, or group of lenders or guarantors in return for that service.  However, an employee may be reimbursed for reasonable expenses incurred in serving on such Advisory Board, Commission or group.

Potential Violations

Potential violations of this Code shall be reported and addressed in a manner consistent with RIT's Compliance Policy and Code of Ethical Conduct, and may result in disciplinary action, up to and including dismissal.  Any questions regarding this Code or a potential violation shall be directed to Verna Hazen, Assistant Vice President & Director of Financial Aid and Scholarships.