Code of Conduct
The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid office personnel. To be compliant, California University of Pennsylvania has developed the following code of conduct that applies not only to Financial Aid Office personnel, but other university employees, officers or agents that may have responsibilities that relate to student loans.
Conflict of Interest
No California University of Pennsylvania employee shall have a conflict of interest with respect to any education loan or other type of financial aid for which the employee has responsibility.
California University of Pennsylvania strictly prohibits any private educational lender from using the University's name, emblem, or logo as well as any words, pictures or symbols associated with the University that would imply endorsement of a particular lender.
Prohibition of gifts
No California University of Pennsylvania employee with Financial Aid responsibilities shall solicit or accept a gift having a monetary value of more than a de minimus amount from a lender, guarantor or servicer of education loans. Examples of gifts include but are not limited to; gift of services, transportation, lodging, meals that were provided by purchase of a ticket, payment in advance, or reimbursement.
Ban on Revenue Sharing Arrangements
California University of Pennsylvania shall not enter into any revenue-sharing arrangement with any lender or other vendor working with the Financial Aid Office. The University shall not accept any fee or other material benefit in exchange for recommending a lender to its students.
Contracting Arrangements Prohibited
No California University of Pennsylvania employee with Financial Aid responsibilities shall accept from any lender or affiliate, any payment or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender.
Interaction with borrowers
California University of Pennsylvania shall not automatically assign a particular lender to any borrower and shall not refuse to certify or delay certification of any loan based on the lender or guaranty agency.
Prohibition on Offers of Funds for Private Loans
California University of Pennsylvania shall not request or accept from any lender, an offer of funds to be used for private education loans in exchange for the University providing the lender with a specified number or volume of federal loans made, or in exchange for placement on a preferred lender list.
Ban on Staffing Assistance
California University of Pennsylvania shall not request or accept from any lender assistance with call center staffing or Financial Aid Office staffing. Lenders, however, may provide professional development training to financial aid administrators and advising materials to borrowers.
Advisory Board Assistance
All California University of Pennsylvania employees with Financial Aid Office responsibilities are prohibited from receiving anything of value from a lender or guarantor in return for service on its advisory board. Reimbursement for reasonable expenses incurred in connection with such service, however, is permitted.