Code of Conduct

No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.
- Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
- The University has no preferred lending agreement with any lender of private educational loans and does not maintain a preferred lender list. Neither the University nor any employee shall enter into any revenue-sharing arrangement with any lender or accept offers of funds for private loans to students in exchange for providing concessions or promises to the lender for a specific number of loans, a specified loan volume, or a preferred lender arrangement.
- A borrower’s choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution. Borrowers will not be auto-assigned to any particular lender.
- No amount of cash, gift, or benefit in excess of a the minimum amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family), or from any entity doing business with or seeking to do business with the institution (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).
- No compensation may be accepted for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.
Institutional award notifications and/or other institutionally provided materials shall include the following:
- A breakdown of individual components of the institution’s Cost of Attendance.
- Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.
- Standard terminology and definitions.
- Renewal requirements for each award.
All required consumer information is displayed in a prominent location on the institutional web site(s) and in any printed materials, easily identified and found, and labeled as “Consumer Information.”
Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.

Statement of Ethical Principles

The primary goal of the institutional financial aid professional is to help students achieve their educational goals by providing appropriate financial support and resources. To this end, this statement provides that the financial aid professional shall:

Advocate for students

Remain aware of issues affecting students and continually advocate for their interests at the institutional, state and federal levels.
Support federal, state and institutional efforts to encourage students to aspire to and plan for education beyond high school.

Manifest the highest level of integrity

Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.
Deal with others honestly and fairly, abiding by our commitments and always acting in a manner that merits the trust and confidence others have placed in us.
Protect the privacy of individual student financial records.
Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.

Support student access and success.

Commit to removing financial barriers for those who want to pursue postsecondary learning and support each student admitted to our institution.
Without charge, assist students in applying for financial aid funds.
Provide services and apply principles that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.
Understand the need for financial education and commit to educate students and families on how to responsibly manage expenses and debt.

Comply with federal and state laws

Adhere to all applicable laws and regulations governing federal, state, and institutional financial aid programs.
Actively participate in ongoing professional development and continuing education programs to ensure ample understanding of statutes, regulations, and best practices governing the financial aid programs.
Encourage colleagues to participate in the financial aid professional associations available to them at the state, regional, or national level and offer assistance to other aid professionals as needed.

Strive for transparency and clarity

Provide our students and parents with the information they need to make good decisions about attending and paying for college.
Educate students and families through quality information that is consumer-tested when possible. This includes (but is not limited to) transparency and full disclosure on award notices.
Ensure equity by applying all need-analysis formulas consistently across the institution’s full population of student financial aid applicants.
Inform institutions, students, and parents of any changes in financial aid programs that could affect their student aid eligibility.

Protect the privacy of financial aid applicants

Ensure that student and parent private information provided to the financial aid office by financial aid applicants is protected in accordance with all state and federal statutes and regulations, including FERPA and the Higher Education Act, Section 483(a)(3)(E) (20 U.S.C. 1090).
Protect the information on the FAFSA from inappropriate use by ensuring that this information is only used for the application, award, and administration of aid awarded under Title IV of the Higher Education Act, state aid, or aid awarded by eligible institutions.
Note: The Higher Education Act does not allow us to share data from your FAFSA directly with certain outside agencies, even with your written permission.

*This was adopted in part from the National Association of Student Financial Aid Administrators’ Statement of Ethical Principles and Code of Conduct for Financial Aid Professionals. The obligations in this Code of Conduct are in addition to any requirements imposed by state or federal laws, or Eastern Oregon University policies.

Employee Code of Conduct

The Higher Education Opportunity Act (HEOA) requires educational institutions to develop and comply with a code of conduct that prohibits conflicts of interest for financial aid personnel [HEOA § 487(a)(25)]. Any Eastern Oregon University financial aid officer or employee who has responsibilities with respect to student education loans must comply with this code of conduct. The following provisions bring Eastern Oregon University into compliance with the federal law [HEOA § 487(e)].

Neither Eastern Oregon University as an institution nor any individual financial aid officer or financial aid employee shall enter into any revenue-sharing arrangement with any lender which makes Title IV loans to students attending the institution.

No financial aid officer or financial aid employee of Eastern Oregon University 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 nominal value.

Gifts and favorable terms and benefits does not include: a brochure, workshop or training using standard materials relating to a loan, default aversion, or financial literacy, such as a part of a training session. Entrance and exit counseling as long as the institution’s staff are in control of the counseling and the counseling does not promote the services of a specific lender.

A financial aid officer or employee at Eastern Oregon University 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.

Eastern Oregon University shall not:

Assign a lender to a first-time borrower through award packaging or any other method; or refuse to certify or delay certification of any loan based on the borrower’s selection of a particular lender or guaranty agency.

Eastern Oregon University 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 specific number of loans made, insured, or guaranteed under Title IV;
A specific loan volume of such loans; or
A preferred lender arrangement for such loans.
An “opportunity pool loan” is defined as a private education loan made by a lender to a student (or the student’s family) that involves a payment by the institution to the lender for extending credit to the student.

Eastern Oregon University shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing.

Any financial aid office employee who has any 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 an advisory board, commission, or group.