Administrator’s Statement of Ethical Principles and Code of Conduct for Institutional Financial Aid Professionals.
The Higher Education Opportunity Act conditions the eligibility of educational institutions to participate in Title IV programs on the development of and compliance with a code of conduct prohibiting conflicts of interest for its financial aid personnel [HEOA § 487(a)(25)]. College officers, employees and agents are required to comply with this code of conduct. The following specific provisions bring St. Michael’s College into compliance with the federal law [HEOA § 487(e)].
- Neither St. Michael’s College as an institution nor any individual officer, employee or agent shall enter into any revenue-sharing arrangements with any lender
- No officer or employee of St. Michael’s College who is employed in the Student Financial Services Office 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.
- An officer or employee of St. Michael’s College who is employed in Student Financial Services who otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, shall not accept from any lender or affiliate of any lender any 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.
- St. Michael’s College shall not: a. for any first-time borrower, assign, through award packaging or other methods, the borrower’s loan to a particular lender; or b. refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
- St. Michael’s College shall not request or accept from any lender any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for the institution providing concessions or promises regarding providing the lender with: a. a specified number of loans made, insured, or guaranteed under Title IV; b. a specified loan volume of such loans; or c. a preferred lender arrangement for such loans.
- St. Michael’s College shall not request or accept from any lender any assistance with call center staffing or financial aid staffing.
- Any employee who is employed in the St. Michael’s College Student Financial Services Office, or who otherwise has responsibilities with respect to education loans or other student financial aid, and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, shall be prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.
As a financial aid recipient, you have the right to:
- Accept, reject, or seek adjustment to your financial aid award without prejudice.
- Know how much aid you will receive per semester and when it will be disbursed.
- Know the terms of any Work Study eligibility you are offered.
- Know the interest rate of any loan offered to you, the amount you must repay, the repayment procedures, the length of time you have to repay the loan, and when repayment begins.
- Access your financial aid file in accordance with the Family Educational Rights and Privacy Act (FERPA).
- Seek financial aid counseling.
- Privacy of information regarding your financial aid information.
- Receive financial aid as long as you are eligible based on federal regulations and provided funds are available.
- Request an appeal on award decisions based on your circumstance, situation, or emergency, that you feel warrants consideration.
As a financial aid recipient, you have the responsibility to:
- Be prepared to provide the expected yearly student and parent resources to cover academic expenses.
- Check your semester financial aid awards against your award letter.
- If necessary, to know the prescribed withdrawal/drop process for courses and to contact the Registrar’s office accordingly.
- Know that if you are in default on any loans and/or owe aid repayments, you will be denied additional aid.
- Know that if you receive aid that exceeds your calculated need, you must repay the excess.
- Notify your work study supervisor if you withdraw from classes.
- Provide accurate factual information on all financial aid forms requested within 30 days of the request.
- Notify the Registrar’s Office of any change in name or address.
- Notify the Student Financial Services Office of any additional financial aid/scholarships that you receive.
- Reapply for financial aid on an annual basis.
- Check your college email account regularly to stay informed and avoid delays and missed deadlines that could affect your aid.
Suspension of Eligibility for Drug Possession or Sale Convictions:
A student who is convicted of any offense under any Federal or State law involving the possession or sale of a controlled substance for conduct that occurred during a period of enrollment for which the student was receiving any Federal Pell, Supplemental Education Opportunity Grant, Federal Work-Study, Federal Perkins loan, Federal Direct Student Loans, Federal Direct PLUS loans, and/or Federal Direct Grad PLUS Loans shall not be eligible to receive any additional grant, loan, or work assistance from the date of that conviction for the period of time specified in the following table:
|OFFENSE||1ST CONVICTION||2ND CONVICTION||3RD CONVICTION|
|Possession||1 year||2 years||Permanent|
A written notice will be provided to each student who has lost eligibility for Title IV federal financial aid funds mentioned above. A student whose eligibility has been suspended may resume eligibility before the end of the ineligibility period by completing an acceptable drug rehabilitation program or by having their convictions overturned. If you have been convicted of a drug offense while receiving
Title IV federal financial aid, you are required to report it on the FAFSA. For additional information on this requirement call a federal representative at 1-800-433-3243.
Notice of Federal Student Financial Aid Penalties for Fraud Violations:
Students who have been convicted of, or who have pled guilty or no contest to a crime involving fraud in obtaining Title IV federal financial aid are not eligible for additional aid until they have repaid the fraudulently obtained funds.