The Higher Education Opportunity Act (HEOA) requires educational institutions to develop and comply with a code of conduct that prohibits conflicts of interest in student financial services. Any Virginia International University officer, employee, or agent who has responsibilities with respect to student educational loans must comply with the code of conduct.
The obligations in this Code of Conduct are in addition to any requirements imposed by state ethics, laws, federal laws, or Virginia International University policies, i.e., the stricter standard of ethical behavior will apply in all instances. The Code of Conduct establishes that:
- Virginia International University (VIU) and its affiliates have no preferred lending agreement with any lender of private educational loans and as such no officer or employee of VIU shall engage in the practice of recommending, promoting or endorsing private educational loans for students attending VIU.
- Neither Virginia International University as an institution nor any individual officer, employee, agent or affiliate employee shall enter into revenue-sharing arrangement with any lender.
- “Revenue-sharing arrangement” includes circumstances where an institution recommends a lender or the loan products of a lender who provides or issues a loan in exchange for a fee or provision of material benefits, including revenue or profit sharing, to the institution, or employee or agent of the institution.
- No officer or employee of Virginia International University who is employed in the office of financial aid or who otherwise has responsibilities with respect to education loans, or agent who has responsibilities with respect to education loans, or any of their family members, shall solicit or accept any gift from a lender, guarantor, or servicer of education loans.
- For purposes of this prohibition, the term “gift” means 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.)
- No officer or employee of Virginia International University who is employed in the office of financial aid or who 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 a 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.
- No officer or employee of Virginia International University who is employed in the office of financial aid or who otherwise has responsibilities with respect to education loans who serves on an advisory board, commission, or group established by a lender or group of lenders shall receive anything of value from such entities, except for reimbursement for reasonable expenses incurred by the employee for serving on such boards, commissions or groups consistent with applicable Virginia International University policies.
- Officers or employees of the office of financial aid at Virginia International University shall not direct borrowers to particular lenders or delay loan certifications. The institution must not:
- For any first-time borrower, VIU will not assign, through award packaging or other methods, the borrower’s loan to a particular lender.
- In addition, the university shall not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender.
- Virginia International University shall not request or accept from any lender any offer of funds for private education loans, including funds for an opportunity pool loan, to students in exchange for the institution providing promises of a specific number of private education loans, a specific loan volume, or a preferred lender arrangement for such loans.
- For purposes of this prohibitions, the term “opportunity pool loan” means a private education loan made by a lender to a student attending the institution or the family member of such a student that involves a payment, directly or indirectly, by such institution of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family.
- Virginia International University shall not request or accept from any lender any assistance with financial aid call center staffing or financial aid office staffing.