Philosophy, Ethics and Code of Conduct

Philosophy

The financial aid program at Wabash College is designed to provide assistance to students who are unable to pursue their education without financial assistance. Although the primary responsibility for meeting college costs lies with the student and parents, the college’s goal is to provide assistance when the family is unable to meet the student’s educational expenses. Financial assistance from Wabash College is viewed as supplementary to the efforts of the student and family.

The financial aid program is also designed to recognize students for outstanding academic performance. We encourage and promote academic excellence through a number of special merit and endowed scholarship programs.

While the primary purpose of our program is to provide financial assistance on the basis of need and academics, the college believes in the intrinsic value of work. Students are encouraged to work on campus as well as to contribute to their educational costs through summer employment.

Selection of students to receive financial aid will be made without regard to age, gender, race, color, religion, national origin, or handicap.

Ethics

The primary goal of the financial aid staff is to help students achieve their educational potential by providing appropriate financial resources. To this end, this statement provides a set of principles that serves as a common foundation for accepted standards of conduct. The financial aid staff shall:

Be committed to removing financial barriers for those who wish to pursue postsecondary learning.
Make every effort to assist students with financial need.
Be aware of the issues affecting students and advocate their interests at the institutional, state and federal levels.
Support efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school.
Educate students and families through quality consumer information.
Respect the dignity and protect the privacy of students, and ensure the confidentiality of student records and personal circumstances.
Ensure equity by applying all need analysis formulas consistently across the college’s full population of student financial aid applicants.
Provide services that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age or economic status.
Recognize the need for professional development and continuing education opportunities.
Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.
Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.
Maintain the highest level of professionalism, reflecting a commitment to the goals of the National Association of Financial Aid Administrators.

Code of Conduct

The financial aid staff are expected to always maintain exemplary standards of professional conduct in all aspects of carrying out their responsibilities, specifically including all interactions with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized or regulated activity. In doing so, the staff must:

1)Refrain from taking any action for personal benefit.

Actions contrary to the obligations of the staff to the college and to students must be avoided. The staff, or a member of the staff’s family, may not accept cash payments, stocks (revenue sharing), club memberships, gifts, entertainment, expense-paid trips, or other forms of inappropriate remuneration from any business entity involved in any aspect of student financial aid. This also relates to actions which may be supportive of the financial aid staff’s work, but are chosen from among alternatives because they also benefit the staff member.

2)Refrain from taking any action that is contrary to law, regulation, or the best interests of the student and parents served.

The financial aid staff works in a complex legal environment. Any doubts as to whether a course of conduct is legally proper should be resolved by referring the matter to the staff member’s supervisor and/or legal counsel for guidance. The staff must adhere to all institutional policies as well as local, state and federal regulations.

3)Ensure that the information provided is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.

Transparency is critical when providing information to students and parents who should be able to fully understand their rights, obligations and their alternatives. The staff is expected to demonstrate transparency, completeness and accuracy in all information. This is especially important as it relates to the college’s private lender list. The staff must ensure that:

Students and their parents understand they are not required to use any of the lenders on the “private lender” list, are free to select any lender they choose, and understand the process for selecting a lender and applying for a loan.
Applications from any lender are promptly certified.
The process through which “private lenders” are selected is fully disclosed and lenders are not assigned to first time borrowers.
Adequate consumer information is provided on “private lenders” such as disclosure of competitive interest rates, terms, and conditions of loans, high quality loan servicing, or additional benefits provided to the student and/or parent.
Information is provided to students and parents on agreements to sell loans to other entities.
The selection of lenders for the “private lender” list is based solely on the history of previous private loan borrowers and represents the best interests of the students and parents who must rely on the list when choosing a lender.

4)Be objective in making decisions and advising the college regarding relationships with any entity involved in any aspect of student financial aid.

The staff must be equitable when recommending or entering into a business relationship with any entity offering a financial aid product or service. A lender maynot be placed on the “preferred lender” list in exchange for a prohibited inducement or based on benefits provided to the college, an employee of the college or students.

Lenders and guarantors may not offer benefits to colleges, financial aid staff or students as listed below. See the Federal Student Aid Handbook for permissible activities. Prohibited inducements include:

Payments (or other benefits);

Including prizes or additional financial aid funds, to a prospective borrower in exchange for applying for a private loan from the lender.
To a school or school-affiliated organization or to any individual in exchange for private loan applications, referrals, or a specified volume or dollar amount of loans made, or placement on a school’s list of recommended lenders.
Provided to a student at a school who acts as a lender’s representative to secure private loan applications.
To a loan solicitor or sales representative of a lender who visits schools to solicit students to apply for private loans from the lender.
To another lender or any other party of referral fees or processing fees, except those processing fees necessary to comply with Federal or State law.
On behalf of an employee of a school or school-affiliated organization to serve on a lender’s advisory board or committee. Non-financial aid school employees can serve on a lender or guarantor board of directors but must recluse themselves from institution related decisions. No other lender contracting or consulting is allowed for any employee of a school.
Of conference or training registration, transportation, and lodging costs for an employee of a school or school-affiliated organization.
Of entertainment expenses, including expenses for private hospitality suites, tickets to shows or sporting events, meals, alcoholic beverages, lodging, rental, transportation, and other gratuities related to lender-sponsored activities for employees of a school or a school-affiliated organization.
For philanthropic activities, including providing scholarships, grants, restricted gifts or financial contributions in exchange for private loan applications, referrals or specified volume or dollar amount of private loans made or for placement on a school’s list of recommended lenders.
For staffing services, either cash or in-kind support, equipment or printing costs to a school, except for services provided to participating foreign schools at the direction of the Secretary, as a third-party servicer or otherwise on more than a short- term, emergency basis, and which is non-recurring, to assist a school with financial aid-related functions.

The staff must not arrange for alternative “opportunity” loans that are not made available to all students or parents. No employee or agent of a lender should ever be identified, either directly or by implication, as an employee or agent of the college.

5)Refrain from soliciting or accepting anything of other than nominal value from any entity (other than an institution of higher education or a governmental agency such as the U.S. Department of Education) involved in the making, holding, consolidating or processing of any student loans, including anything of value (including reimbursement of expenses) for serving on an advisory body or as part of a training activity of or sponsored by any such entity.

Staff must not only avoid conflicts of interest that arise when actually accepting a benefit from a lender but must also avoid benefits received that create the appearance that the staff member may not be impartial or may not be acting in the best interest of the student. Therefore soliciting or accepting of anything of other than nominal value ($10) is prohibited. Staff may not receive remuneration for service on a lender advisory board, even if only reimbursement for expenses, or for professional development training activities.

6)Disclose to the college any involvement or interest in any entity involved in any aspect of student financial aid.

Staff must avoid any investment in or financial relationships with lenders and similar entities and abide by college conflict of interest policies with regard to involvement, investment or interest in a financial aid-related entity.