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:


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 de minimus 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.

For information on Villanova University Charles Widger School of Law's leave of absence policy and/or withdrawal policy, J.D. students should see the Villanova University School of Law Student Handbook and Graduate Tax Students should see the Graduate Tax Program brochure.  Students contemplating withdrawing or going on a leave of absence from either program should contact either the Associate Dean for Academic Affairs (J.D. students) or the Director of the Graduate Tax Program (Graduate Tax students) in addition to the Office of Financial Aid.

In most cases for the purposes of financial aid, students are considered as withdrawn and thus going into their grace/repayment period on their loans unless they can meet the following requirements which would entitle them to a leave of absence status:

  • The leave of absence cannot exceed 180 days in any 12-month program.
  • The student must be able to return to the program at the point where the student interrupted the program.  


Return of Title IV Federal Financial Aid

When a student who has received Title IV aid such as a Federal Direct Unsubsidized Loan, Federal Graduate PLUS Loan, or Federal Perkins Loan withdraws or goes on a leave of absence from the law school, the institution must determine the amount of aid that has been earned as of the date of withdrawal or leave.  Earned aid may have been used to pay for institutional charges such as tuition and fees or non-institutional costs such as books and living expenses.  Title IV aid that is considered unearned aid must be returned to the appropriate programs.

If the student has completed more than 60% of the semester, he is considered to have earned 100% of his Title IV aid for that term and therefore there is no unearned aid that must be returned to the Title IV programs.  If the student has completed 60% or less of the semester, then the amount of aid that has been earned is equal in percentage to the percentage of the semester that has been completed.  For example, in a semester that is 115 days and the student withdraws on the 30th day, then 26% of the semester has been completed and 26% of the Title IV aid has been earned.

Unearned aid must be returned to the Title IV programs in the following order:

  1. Federal Direct Unsubsidized Loan Program
  2. Federal Perkins Loan
  3. Federal Graduate PLUS Loan
  4. Other grant or loan assistance authorized by Title IV of the HEA

If Title IV funds do not exceed institutional charges, then the institution must return the unearned funds.  If Title IV funds exceed institutional charges, then the responsibility to return the unearned portion is divided between the institution and the student because both hold some portion of the Title IV funds.  If the student is required to return funds to a loan program, that money is repaid under the terms and conditions of the promissory note.

If the student did not receive all of the funds that were earned, the student may be due a post-withdrawal disbursement.  If the student's post-withdrawal disbursement includes loan funds, the institution must get the student's permission before it can disburse these funds.  The student can decline some or all of the loan funds to prevent additional loan debt.

For further information on this policy and for examples of how the return of Title IV funds is calculated, please visit the Office of Financial Aid in the Student Services wing, email finaid@law.villanova.edu or call 610-519-7015.


Refunds of Other Aid

For aid other than Title IV aid (such as an alternative loan), the calculation of how much aid has been earned and how much aid must be returned to the various programs is the same as described above for Title IV aid.

In order to maintain eligibility for all federal financial aid programs, a student must be making satisfactory academic progress.  Students receiving any form of federal financial aid must adhere to the standards for satisfactory academic progress as outlined in the Academic Rules and Policies section found in the Student Handbook.  Failure to maintain satisfactory academic progress may result in the suspension or termination of financial aid.

Satisfactory Academic Progress Policy

Federal regulations mandate that the Office of Financial Aid monitor each student’s academic progress towards degree completion. The following policy explains the requirements which must be met by each student at the end of each payment period. To comply with the Satisfactory Academic Progress Policy (SAP), students must maintain both qualitative and quantitative standards, as defined below:


  • Grade Point Average (G.P.A.):       Year in School       Required G.P.A.

             (Qualitative Standard)                             1L                           2.0

                                                                             2L                           2.0

                                                                             3L                           2.0                                                                 

              Graduate Tax Program                                                        2.0


  •  Credits Completed:  (Quantitative Standard)                       

         Measured by credits attempted (including withdrawals, failures and                   incompletes) to credits completed successfully. A passing grade(A,B,C,D,          or  P) must be received for at least 67% of all credits attempted.


Students who fail to meet these standards will be placed on financial aid warning and only awarded aid for one semester.  The Office of Financial Aid will send written notification and a copy of the Satisfactory Academic Progress Policy to the student. Those students who do not make satisfactory academic progress during this warning semester will be ineligible for financial aid.

A student may appeal this decision to the Financial Aid Academic Appeal Committee (FAAAC) one time. The appeal will require the student to submit a written statement, to the Office of Financial Aid, detailing the circumstances that prohibited successful completion of their coursework. If supporting documentation is available to substantiate those circumstances, a student should also supply copies to the Office of Financial Aid. As a federal requirement, a student must consult their academic advisor to establish their academic plan for future success. The FAAAC will determine if the appeal is granted and then notify the student.

If an appeal is granted, a student will be placed on a probationary period for one semester. At the end of the semester, the student’s grades will be reviewed to determine if they are making satisfactory academic progress and adhering to their academic recovery plan. A review will take place on a semester basis until the student meets the SAP standards. If SAP recovery requires more than one semester, the FAAAC will determine, on a case by case basis, if the duration of probation should be for two semesters.