Student Loan Code of Conduct for Employees
All Boston College employees whose job responsibilities include matters related to student financial aid are expected to maintain exemplary standards of professional conduct and must adhere to this Code of Conduct in compliance with Federal regulations. The Executive Director of Student Services shall notify these employees annually of their obligations under this Code.
- Prohibits all revenue-sharing arrangements with lenders. The University will not promote or recommend any lender in exchange for a fee or other material benefit from that lender.
- Does not request or accept offers of funds for private loans, including opportunity pool loans.
- Certifies loans from any lender selected by a borrower without undue delay, and will not direct a first-time borrower’s loan to a particular lender.
- Ensures that the process through which the student signs a Master Promissory Note preserves the student’s right to select the lender of his or her choice.
- Does not arrange for alternate loan programs that disadvantage students or parents not enrolled in the program or receiving such loan terms.
- Prohibits the request or acceptance of staffing assistance from lenders.
- Prohibits employees or agents of a lender from identifying themselves, either directly or by implication, as an employee of Boston College to students, parents or any persons seeking information from Boston College.
- Bases the selection of lenders for a preferred lender list solely on the best interests of the students and parents.
- Fully discloses the selection process for a preferred lender.
- Provides borrowers with consumer information about the loan products offered by the lenders on a preferred lender list, including any agreements lenders have to sell their loans to other entities.
- Informs students and parents that they are not required to use any of the lenders on a preferred lender list and can select any lender of their choice.
Every Boston College employee involved in any aspect of the loan process (this includes, but is not limited to, the Financial Aid staff, both on the main campus and at the Law School, and the Enrollment Management staff) must avoid any situations that create a potential conflict of interest between the employee’s personal or outside interests and his or her role and responsibilities as an employee of Boston College, and must disclose to his or her supervisor any potential conflict as it arises.
Specifically, staff members must not:
- Solicit or accept gifts with more than a de minimis value from any business entity involved in any aspect of student financial aid, including, without limitation, cash payments, stocks, club memberships, favors, discounts, lodging, meals, entertainment, and services. This prohibition extends to a staff member’s family (includes staff member's and spouse's: parent or stepparent; sibling or step-sibling; child or stepchild; and grandchild or step-grandchild, as well as a child's spouse and a sibling's spouse).
- Undertake any activity, whether compensated or not, outside of Boston College that has the potential to create a conflict of interest with the staff member’s duties as a financial aid professional employed by Boston College, including accepting any fee, payment, or other financial benefit as compensation for any type of employment, consulting or other arrangement with a lender, guarantor, or servicer.
- Receive any compensation for serving on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors. A staff member wishing to serve on an advisory board must seek prior approval from his or her supervisor, and may be reimbursed only for reasonable expenses while serving on an approved advisory board.
Staff members should understand and adhere to all institutional policies and any local, state and federal requirements that are applicable to their conduct or job performance. Any staff member who has a question whether a particular situation or activity creates a conflict of interest or violates any law or policy should immediately notify their supervisor prior to commencing such activity, or at the earliest time when such a question arises. Supervisors shall contact the Office of the General Counsel upon receipt of any inquiries.