Financial Aid Code of Conduct
In the administration of its student financial assistance programs Villanova University (VU) abides by the National Association of Student Financial Aid Administrators (NASFAA) Statement of Ethical Principles. In addition, Villanova University has adopted a Code of Conduct for Financial Aid which can be found below.
Villanova University’s Code of Conduct for Financial Aid
Villanova University abides by the following Code of Conduct, which is intended to comply and be interpreted in conformity with the Higher Education Opportunity Act of 2008:
No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.
Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
Loan Award and Certification
Villanova University shall not assign any first-time borrower’s education loans, through award packaging or other methods, to a particular lender.
Villanova University shall not refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
Ban on Receipt of Gifts
No officer, employee or agent of Villanova University shall solicit or accept any “gift” from a lender, guarantor, or servicer of education loans. “Gift” includes any gratuity, favor, discount, entertainment, hospitality, loan or other item having monetary value of more than a minimal amount.
This prohibition also applies to gifts to family members of the above individuals when the gift was given with the knowledge and acquiescence of such individual, and the individual has reason to believe the gift was given because of such individual’s official position.
Ban on Revenue-Sharing Arrangements
Villanova University will not enter into any “revenue-sharing arrangement” with any lender. A “revenue sharing arrangement” is an arrangement whereby the University recommends a lender of educational loans, and then in exchange, the lender pays a fee or provides other material benefits, including revenue or profit-sharing, to the University, or an officer, employee or agent of the University.
Ban on Contracting Arrangements with Lenders
No officer or employee of Villanova University who is employed in the financial aid office of the University or otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, shall accept from any lender or affiliate of any lender any fee, payment or other financial benefit (including the opportunity to purchase stock) 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.
Ban on Offers of Funds for Private Loans
Villanova University shall not request or accept from any lender any offer of funds to be used for private education loans for students, including funds for an “opportunity pool loan,” in exchange for the institution providing concessions or promises to provide the lender with: (i) a specified number of loans made, insured or guaranteed; (ii) a specified loan volume; or (iii) a preferred lender arrangement.
An “opportunity pool loan” means a private education loan made by a lender to a student attending the University or a family member of the student, that involves a payment, directly or indirectly, by the University of points, premiums, additional interest, or financial support to the lender for the purpose of the lender extending credit to the student or the student’s family.
Ban on Staffing Assistance
Villanova University shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing. However, this prohibition does not preclude requesting or accepting assistance from a lender related to: (i) professional development training for financial aid administrators; (ii) providing educational counseling, financial literacy or debt management materials to borrowers that identify the lender who assisted in preparing or providing the materials; or (ii) staffing services on a short term, nonrecurring basis to assist the University with financial aid-related functions during emergencies.
Ban on Compensation for Service on Advisory Board
No employee who is employed in Villanova University’s 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 of lenders or guarantors, shall be permitted to receive anything of value from the lender, guarantor, or group of lenders or guarantors, except for reimbursement for reasonable expenses incurred in serving on such advisory board, commission, or group.