Code of Conduct

Institutional members of NASFAA will ensure that:

1. 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.
• If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete and accurate. The complete process through which preferred lenders are selected will be fully and publicly disclosed. Borrowers will not be auto-assigned to any particular lender.
• A borrower's choice of a lender will not be denied, impeded or unnecessarily delayed by the institution, even if that lender is not included on the institution's preferred lender list.
• No amount of cash, gift or benefit in excess of a de minimis 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).

2. Information provided by the financial aid office is accurate, unbiased and does not reflect preference arising from actual or potential personal gain.

3. Institutional financial aid offers and/or other institutionally provided materials shall include the following:

• A breakdown of individual components of the institution's Cost of Attendance, designating all potential billable charges.
• Clear identification of each award, indicating type of aid—i.e. gift aid (grant, scholarship), work or loan.
• Standard terminology and definitions using NASFAA's glossary of terms.
• Renewal requirements for each aid being offered.

4. 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."

5. 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.

In addition to the above statements, all staff members have received a copy of NASFAA’s Statement of Ethical Principles and Code of Conduct for Institutional Financial Aid Professionals and have agreed to abide by them.

The Higher Education Opportunity Act (HEOA) requires educational institutions to develop and comply with a code of conduct that prohibits a conflict of interest for financial aid personnel [34 CFR 668.14(b)(27)]. Any Texas State University officer, employee or agent who has responsibilities with respect to student educational loans must comply with this code of conduct and be informed annually of the provisions of the code.

Texas State University has no preferred lender agreement with any lender of private educational loans and as such no officer or employee of the university shall engage in the practice of recommending, promoting, or endorsing private education loans for students attending the university.

Financial aid personnel, TXST One Stop personnel, Texas State officer, employee, or agent shall not enter into any revenue sharing arrangements with any lender.

No employee of Texas State University who is employed in the financial aid 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.

An employee of Texas State University who is employed in the financial aid office or 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 benefits as compensation for any type of contracting agreement.

Texas State University shall not direct borrowers to particular lenders or refuse to certify, or delay certification of any loan based on the borrower’s selection of a particular lender or guarantee agency.

Texas State University shall not request or accept from any lender any offer of funds to be used for private education loans.

Texas State University shall not request or accept from any lender any assistance with financial aid call center staffing.

Any Texas State University employee who is employed in the financial aid 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.

FAS 3/6/2024