Student Loan Code of Conduct

A conflict of interest exists when your personal interests could interfere with your obligation to act in the best interests of students or the University. As a Covered Employee, you must avoid both actual and perceived conflicts of interest. You must:

1. Avoid conflicts between your university responsibilities and any dealings with Education Lenders or Services involved with student financial aid at SMSU.
2. Not accept fees, payments, or other financial benefits from and Education Lender or Servicer, except as specifically allowed in this Code.
3. Not serve as a paid or unpaid member of a board of directors for any Education Lender or Servicer.
4. Not serve as a paid or unpaid consultant or employee for any Education Lender or Servicer.
5. Not serve on an Education Lender’s advisory board without prior approval from the SMSU Vice President for Finance and Administration.

1. You may not solicit or accept gifts from any Education Lender or Servicer. A gift includes anything valued over $10. If you receive an unsolicited gift, decline it and promptly notify the SMSU Director of Financial Aid. Family members or close friends should also not accept gifts offered because of your University position.
2. You may accept modest foods, refreshments, training, or informational materials as part of lender- or servicer-sponsored training that enhances professional development and improves services to students.
3. If you are invited to meals, entertainment, or similar events not related to training, you must pay your own expenses. Reimbursement may be requested in accordance with the University policy.
4. A “gift” does not include educational materials of programs focused on loan products, debt management, default aversion, or financial literacy, provided:
   1. Students are informed of the Education Lender’s or Servicer’s involvement, and
   2. Printed materials include the provider’s name and do not display University logos.
5. The University may use online entrance and exit counseling tools offered by Education Lenders or Servicers if:
   1. The University controls the counseling context and delivery; and
   2. The counseling does not promote specific lender products or services.

1. You may not assign a first-time borrower’s private loan to a particular Education Lender, nor may you delay or refuse loan certification based on the borrower’s lender choice.
2. You must inform students that they may select any Education Lender, regardless of whether that lender appears on the University’s open lender list.

1. The University will not accept access to or preferential terms on private education loans in exchange for loan applications, loan volume, or lender list placement.
2. Education Lenders or Servicers may provide non-lending services to the University only if the University pays market rates and if no advantage is given in return regarding education loans.
3. The University may accept scholarships or philanthropic contributions from Education Lenders or Services if the contributions are unrelated to education loans. Any such offer must be reported to, and approved by, the SMSU Director of Financial Aid before acceptance.
4. The University may accept state-administered grants, scholarships, or financial aid funds from or on behalf of the State of Minnesota

The University will not accept any fees or benefits from an Education Lender in exchanges for placement on an open lender list.

The University may not request or accept staffing or call-center assistance for the financial aid office from any Education Lender, regardless of whether the lender intends to charge for such services.

If you have questions about this Code of Conduct or become aware of a potential violation, contact:

• SMSU Director of Financial Aid, or
• SMSU Vice President for Finance and Administration