The Student Loan Sunshine Act
Code of Conduct for Staff in the Office of Scholarships and Financial AId
Background:
The Student Loan Sunshine Act was passed by the House of Representatives on May 9, 2007. The core principles of the Act have been incorporated into the Higher Education Opportunity Act of 2008. Families can find additional information on this Act in the legislation section of our website.
Families should note that staff working in the Office of Scholarships and FInancial Aid at Loyola University New Orleans have not been implicated in any of the current investigations into practices in the student loan Industry. We
- do not have any revenue-sharing agreements with lenders;
- have not accepted any offers of funds from lenders to be used for private educational loans (also known as "opportunity pools") in exchange for processing federal or private loans for a particular lender.
- have not received gifts of stock or other financial compensation from lenders in return for service on a lender's advisory board. No staff members serve on any lender advisory boards.
Staff members in the Office of Scholarships and Financial Aid have always been bound to act in compliance with the vision outlined in our Mission Statement and the National Association of Student Financial Aid Administrator's Statement of Ethical Principles and Code of Conduct for Institutional Financial Aid Professionals. This updated Code was released on May 31, 2007.
Although the Student Loan Sunshine Act will not become law until matching legislation is passed by the U.S. Senate, staff members in Office of Scholarships and Financial AId will be bound by the following explicit guidance effective May 9, 2007. This guidance is based on information sent from the American Council on Education. This guidance may be updated after action by the U.S. Senate on this legislation as well as Congressional action on the Reauthorization of the Higher Education Act ("HEA").
- No staff member shall accept any gift worth more than $10 from a representative of a student loan provider. Gifts include meals, travel, lodging, entertainment, and in-kind services (such as printing customized consumer information for borrowers with the school's logo).
- Staff can participate in meals, refreshments, and receptions in conjunction with meetings, trainings, or conference events open to all attendees.
- On a space available basis, staff will contintue the practice of putting all unsolicited marketing materials (such as pens, pads and markers) received from lenders out in the reception area for the use of students and parents. This practice may be amended or discontinued pending further legislative action. A basic "rule of thumb" - anything that can be used by the students is apparently OK. Gifts that are earmarked only for the staff are not.
- These guidelines will apparently allow the staff to accept , for example, one unsolicited plate of cookies or box of do-nuts (assuming the total dollar value is $10 or less ) from a lender during a visit to the aid office. We are interpreting the current legislation to mean that the $10 cap applies to the entire office and not to individual staff members.($10 x 8 staff members).
- Office visits by representatives of major lenders are normally limited to once a quarter.
- Interested Lender representatives are invited to speak at staff meetings during the late fall and winter to provide updated information on their programs for families.
- Small print pieces used to help meet Federal Consumer Information mandates that were received early in 2007 before this legislation was proposed will be used for the remainder of the 2007-2008 processing year or until banned by further legislative/regulatory activity. Lenders who volunteered to print these supplemental pieces did not receive preferential treatment within the Office of Scholarships and Financial Aid as a result of this support. These pieces will be done internally once the 2007-2008 budget year begins.
- Staff members are free to pursue part-time employment outside of their scheduled work day. However, any staff member who is approached by a lender with an offer for supplemental employment will provide full written details to his/her supervisor. Staff members can not accept supplemental employment with lenders that creates any potential "conflict of interest" with the operations of the Office of Scholarships and Financial Aid.
- Staff members shall not accept any remuneration or expense-reimbursement for serving as a member of a lender's advisory board. Staff may participate on advisory boards that are unrelated in any way to higher education loans.
- Loyola University New Orleans does not currently require staff to complete and submit financial disclosure forms as a condition of employment. All staff members in the Office of Scholarships and Financial Aid will disclose to his or her immediate supervisor if an assigned task could create a perceived or real "conflict of interest" in the eyes of the public.
Staff who knowingly fail to follow these guidelines will be subject to normal disciplinary guidelines.
Lender Participation in On-Campus Special Events
As a service to our families, we have historically invited - on a space available basis - representatives from the student lending community as well as the Louisiana TOPS Program to participate in the President's Open House . Our parents have indicated that they appreciate the opportunity to speak with a "real person" about questions that they have. These special events are not housed within the Office of Scholarships and Financial Aid AND the lenders are always clearly identified . We believe that continuing this program does provide families with the opportunity to gather additional information which helps them become better consumers.
Based on our current understanding of the legislative intent behind the Student Loan Sunshine Act, we believe that we can continue to offer this service to our families.
