Policies

Each applicant has the right to know:

• What financial aid programs are available at Concordia University.
• The deadlines for submitting applications for available financial aid programs.
• How financial aid is distributed, how decisions are made and the basis for those decisions.
• How financial need and budgets (including costs for tuition, fees, room, board, books, supplies, personal and miscellaneous expenses) are determined.
• What resources (such as parental contribution, other financial aid, student assets, etc.) are considered in the need calculation.
• How much of the financial need, as determined by the University, has been met.
• The explanation of the various programs included in the aid package.
• The University's refund policy.
• What portion of the financial aid is grant/gift (non-repayable) and what must be repaid.
• How the University determines whether the applicant is making satisfactory progress and what happens if he/she is not.

Each applicant is responsible for:

• Completing all application forms accurately and honestly and providing the Financial Aid Office with correct information. Reporting incorrect information is a violation of the law.
• Maintaining satisfactory academic progress as defined in the Concordia University general catalog.
• Returning all additional documentation, verification, corrections and/or information requested.
• Reading and understanding all forms that must be signed and accepting responsibility for the agreements signed.
• Performing the work that is agreed upon in accepting a Work­ Study award.
• Complying with all deadlines for application and reapplication for Concordia University financial aid.
• Being aware of the refund procedures when withdrawing from Concordia University.
• Receiving clearance from the Financial Aid Office before dropping below full­-time status or before withdrawing from Concordia University.

General Conditions of Financial Aid Offer

You must promptly report to the Financial Aid Office any changes in your financial, marital, residency or academic status. Any additional financial assistance you receive will be added to your offer. This may result in a reduction of your offer and/or require repayment of financial aid funds already advanced to you during the academic year. You agree to accept repayment responsibility of any loans you accept. When you graduate, withdraw, or cease to be a half-time student, you must complete Exit Counseling. If you wish to reject any aid listed on your Financial Aid Award, you must notify the Financial Aid Office.

Regarding Notice of Financial Assistance

This notice of financial assistance is based on the documented financial information you submitted on your FAFSA. It is your responsibility to inform the Financial Aid Office if your reported information changes in any way during the academic year for which you are accepting financial aid. If you believe this award is based upon incorrect information, you may request that the Financial Aid Office review your application using documented information that you must provide.

General Conditions of Financial Assistance

1. Concordia University Irvine reserves the right to revise your Financial Aid Offer. Modification may be required by lack of necessary state or federal funding, corrections or changes in the data reported to the institution by parents and/or students, receipt of additional awards by non-college sources, unintended error, change in unit load, change in residency, or other reasons consistent with Concordia University Irvine policy and procedures.
2. While some financial aid is conveniently credited against your student account with Concordia University Irvine, there are some types of funding in which checks must be made in your name. If these funds are necessary to cover charges due to Concordia University Irvine, the checks must be signed in the Financial Aid Office.
3. If you fail to maintain satisfactory academic progress towards your degree, you may be denied future financial aid. Satisfactory academic progress is defined in the college catalog.
4. Many financial aid programs are designed to assist you for no more than 4 years of undergraduate work.
5. You must be enrolled in coursework towards your degree and/or program at least half-time to receive Title IV aid and at least full-time to receive institutional aid. If you withdraw or cease to carry the required number of units, you must make arrangements with the Bursar to repay any aid advanced to you for which you are no longer eligible
6. Your financial aid, including Cal Grant B Access stipend, will be credited to any current year tuition, fees, and university room and meal plan on your student account. By accepting your Financial Aid Offer, you authorize the Financial Aid Office to credit your current financial aid award towards any other current educationally-related charges on your student account. If you revoke this authorization, you must pay all other charges from personal funds. You have the option to rescind your Cal Grant B Access from crediting to your student account.

Notice to Cancel Loans

Federal loans may be canceled or reduced in size by refusing to accept any disbursement that is issued. Requests to cancel or reduce federal loans must be submitted in writing to the Financial Aid Office.

You Must Inform the Financial Aid Office if the Following Conditions Apply to You

1. Reduction in unit load: if your enrollment status changes a revision of your financial aid may be required.
2. Change in residency or marital status: your Financial Aid Offer indicates where you reported you would be living this academic year. If this is incorrect or you change your residency or marital status, you must notify the Financial Aid Office.
3. Withdrawal: you must notify the Registrar’s Office if you leave Concordia University Irvine for any reason. If you withdraw from Concordia University Irvine before the end of the semester, your financial aid will be adjusted in accordance with Concordia University Irvine and Federal Government Refund Policies.
4. Increase in resources: if you receive any additional resources during the academic year, you are obligated to inform the Financial Aid Office so that your financial aid may be re-evaluated and/or adjusted. This assures that the limited funds available will assist the greatest number of students with the highest need (including earnings).

Statement of Educational Purpose

I declare that I will use any funds I receive under the PELL GRANT, SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT, FEDERAL DIRECT STAFFORD LOAN PROGRAMS or STATE GRANT PROGRAMS for expenses connected with attendance at Concordia University Irvine.

A student may not participate in graduation ceremonies, register for further sessions, or receive any diploma, certificate, transcripts, or Degree Verification Letter until all financial obligations have been satisfied with a zero balance. Concordia University, Irvine, herein the university, as a security interest, shall retain any diploma, certificate, transcripts, or letter of recommendation until all such obligations are satisfied. Release of any such security interest prior, or subsequent to, any default by the debtors shall not be considered a binding precedent or modification of this policy.

The university reserves the right to make any changes in costs, payment plans, and refund policies without notice.

The university will attempt to inform students about deadlines and procedures, but the final responsibility for the timely filing of the FAFSA and related documents is the student’s. The university’s official means of communication is the student’s eagles email account.

The student must notify the Financial Aid Office regarding changes in financial situation, marriage, loss of a job, change in class load, withdrawal from school, or change of address. In order to contact the Financial Aid Office, a student may email, call, or visit in person.

As active institutional members of the National Association of Student Financial Aid Professionals (NASFAA), the Financial Aid employees at the university prescribe to the NASFAA Code of Conduct. The Code of Conduct is intended to assist financial aid professionals in carrying out their obligations, particularly with regard to ensuring transparency in the administration of the student financial aid programs, and to avoid the harm that may arise from actual, potential, or perceived conflict of interest.

The Higher Education Opportunity Act of 2008 legislated requirements, which prohibits a conflict of interest with the responsibilities of an officer, employee, or agent of the university regarding Title IV loans. The term "employees" refers to any of the university's officers, employees and agents who are employed in the financial aid office or who have responsibilities with respect to student loans or who have responsibilities with respect to student loans related to Title IV education loans or private loans for educational purposes.

The Code of Conduct Establishes that:

• Employees shall not enter into any revenue-sharing arrangement with any lender where the lender provides or issues a Title IV loan to the student or student's family in exchange for the university recommending the lender or the lender's loan products in exchange for a fee or material benefit including profit or revenue sharing that benefits the university or a university's employee or agent.
• Employees shall not solicit or accept any gift in the form of a gratuity, favor, discount, entertainment, hospitality, loan, service, transportation, lodging, meals, reimbursement, or other item having a monetary value of more than a nominal amount from a lender, guarantor, or servicer. Certain items and services are exempt from the definition of "gift". Gifts and favorable terms and benefits do 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.
• Employees must not accept any fee, payment, or other financial benefit (including the opportunity to purchase stock) from a lender 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.
• The university shall not request or accept funds from any lender for private education loans including funds for an opportunity pool loan to its students in exchange for the university providing promises of a specified loan number or volume or a preferred lender arrangement for educational loans.
• Employees shall not assign, through award packaging or other methods, a first-time borrower's loan to a particular lender or refuse to delay processing of a loan based on the borrower's selection of a lender or guarantor.
• Employees shall not accept or request any assistance with call center or financial aid office staffing from any lender except as allowed by law.
• Employees who serve 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, group of lenders or guarantors. However, the employee may be reimbursed for reasonable expenses incurred in serving on the advisory board, commission, or group.

Office of Financial Aid does not discriminate on the basis of race, color, national origin, sex, age, disability, or status as a veteran in any of its policies, practices, or procedures.

This policy is in effect as a result of the Higher Education Amendments of 1998 (HEA 98). The Federal Title IV programs covered under this policy include Federal Pell Grant, Supplemental Educational Opportunity Grant (SEOG), Federal Direct Stafford Loan, Federal Direct Parent and Grad PLUS Loans. A student withdrawing from the university during a semester must file an Official Withdrawal Form with the Office of the Registrar. If a student is not able to visit the office, he/she may contact a staff person in the Registrar’s Office regarding the withdrawal date. The university will determine the student’s official withdrawal date as: 1) the date the student began the university’s withdrawal process; 2) the midpoint of the semester, if the student withdraws without notifying the university; or 3) the student’s last date of attendance at an academically related activity, as documented by the university.

If the student begins the withdrawal process and then later decides to continue attendance at the university, the student must indicate this in writing to the Office of the Registrar and indicate that his/her intention is to complete the semester.

If the student withdraws during a semester, the portion of the federal grants and loans a student is entitled to receive is calculated on a percentage basis by comparing the total number of days in the semester to the number of days that the student completed before he/she withdrew. If the percentage earned is sixty percent (60%) or greater, the student is considered to have earned one hundred percent (100%) of eligibility. This policy does not affect the student’s charges. The university’s withdrawal policy will be used to determine the reduction, if any, in the student’s tuition, room and board charges. The university refund policy is determined by a weekly percentage until the sixty percent (60%) or greater point in the semester is reached. If it is determined that a portion of the financial aid received on the student’s behalf is unearned, the university shares with the student the responsibility of returning those funds. Any grants and loans that a student is required to return to the federal programs are considered an overpayment. The student must either repay the amount in full or make satisfactory payment arrangements with the Department of Education to repay the amount. If the student fails to repay or make arrangements to repay an overpayment, the student will lose his/her eligibility to receive future federal financial aid at any institution.

Order of Return of Title IV Funds

• Funds will returned to the SFA Programs in the following order:
  1. Federal Direct Unsubsidized Loans
  2. Federal Direct Subsidized Loans
  3. Federal Perkins Loans
  4. Federal Direct PLUS loans received on behalf of the student
• After repaying all loan amounts, any remaining funds must be returned in the following order:
  1. Federal Pell Grants for which a Return is required
  2. FSEOG Program for which a Return is required
  3. TEACH Grants for which a Return is required
  4. Iraq and Afghanistan Service Grant for which a Return is Required

Timeframe for the Return of Title IV Funds

• Return of Title IV: As soon as possible, but no later than 45 days after the date the school determined the student withdrew, the school must return unearned funds for which it is responsible.
• Post-Withdrawal Disbursement to Account: As soon as possible, but no later than 180 days after the date the school determined the student withdrew, the school must credit the student's account with the grant or loan funds for outstanding current charges and minor (under $200) prior year charges.
• Post-Withdrawal Disbursement to Student: For earned Title IV funds in excess of outstanding current charges. As soon as possible after the date the school determined the student withdrew
  • Loans: no later than 180 days
  • Grants: no later than 45 days

Treatment of Title IV Credit Balances when a Student Withdraws

1. Do NOT release any portion of a Title IV credit balance to the student and do NOT return any portion to the Title IV programs prior to performing the Return calculation.
2. Perform the Return Calculation, including any existing Title IV credit balance for the period in the calculation as disbursed aid.
3. Apply any applicable refund policy (state, accrediting agency, institutional) to determine if doing so creates a new or larger Title IV credit balance.
4. Allocate any Title IV credit balance as follows:
   • Any Title IV credit balance must be allocated first to repay any grant overpayment owed by the student as a result of the current withdrawal.
   • Within 14 days of the date that the institution performs the Return Calculation, the institution must pay any remaining Title IV credit balance funds in one or more of the following ways:
     • In accordance with cash management regulations to pay authorized charges at the institution, including previously paid charges that are now unpaid due to a R2T4 by the institution
     • A school may not use a Title IV credit balance to return funds for which it is responsible as a result of a Return calculation: STEP 5, item O.
     • With the student's authorization, to reduce the student's Title IV loan debt (not limited to loan debt for the period of withdrawal) or
     • To the student (or parent for the PLUS loan). If the institution cannot locate the student or parent whom a Title IV credit balance must be paid, it must return the credit balance to the Title IV programs. The Department does not specify the order of return to the Title IV programs for a credit balance. Institutions are encouraged to make determinations that are in the best interest of the individual student.

The U.S. Department of Education has specific regulations that govern the R2T4 calculation for students enrolled in modular courses. Modular courses are defined as those that do not span the entire length of the term and are offered sequentially rather than concurrently (although it is possible for modules to overlap). At the university, Session 1 and Session 2 sessions would be considered modules for financial aid purposes.

Regulations require the entire period and combination of modular courses to be considered when determining the portion of financial aid that has been earned by a student who withdraws. The student is considered withdrawn when s/he fails to complete the scheduled enrollment. At this point, the percentage of completion is calculated by dividing the number of completed days by the number of days the student was scheduled to attend. (Scheduled breaks of at least five days are omitted from the calculation.) The fact that a student completes at least one course is no longer a valid reason for not doing the calculation.

A student who withdraws from a current module but provides written confirmation of plans to return and attend a future module that begins within 45 days of the end of the current module is considered to still be enrolled.

If the student provides written confirmation but then fails to attend a future module, the student is considered withdrawn from the initial date of the original module. If the student withdraws without a written confirmation to attend in the future but returns during the same period, the student is able to receive all funds for which the student has eligibility according to their current enrollment status.

Students withdrawing from the university or dropping courses within the refund period may be eligible for a refund of charges in accordance with the university's fee schedule and refund procedures. Students who withdraw from the university after classes begin may apply for a refund (i.e., tuition, room, board) by contacting the Bursar's Office. The student is responsible for paying any outstanding charges to the university. Dropping courses or withdrawing from the university may or may not result in a credit on the student's account. Please contact the Bursar's Office for further information or www.cui.edu/refunds.

It is understood that by applying for financial aid, the student grants the Financial Aid Office the right to release the learner’s grades and enrollment records to scholarship, state, federal, and loan agencies as needed.

Federal regulations require all schools participating in Title IV financial aid programs to have a Satisfactory Academic Progress (SAP) policy. Title IV financial aid programs include: Pell Grant, Supplemental Educational Opportunity Grant (SEOG), Federal Direct Subsidized Stafford Loan, Federal Direct Unsubsidized Stafford Loan, Federal Direct PLUS Loans, and Work-Study. The requirements of this policy apply to all Title IV and non-Title IV students receiving federal and state aid, and institutional aid per university policy.

Minimum Standards

To remain eligible for federal grants, loans, and work-study, students must meet the standards indicated below at the end of each semester. Please note the standards to establish and maintain eligibility for Title IV assistance are more stringent than the University’s academic standards for continuous enrollment. At the end of each term of enrollment, students must earn the minimum cumulative GPA, minimum number of credit hours, and be within the maximum timeframe. Failure to meet the minimum cumulative standards may result in a loss of financial aid eligibility.

• Qualitative Measure of Progress

  The qualitative requirement sets a minimum Cumulative Grade Point Average (GPA) for the degree level at which a student is classified. Note: This is the GPA used to determine one’s status and includes grades from courses taken at all other schools that are accepted by the university. To remain in compliance, a student must maintain the following cumulative GPA after each period of assessment:

  • Minimum Cumulative GPA for undergraduate students is 2.0
  • Undergraduate academic scholarship requires a cumulative GPA 2.5
  • Undergraduate Honor’s Scholarship requires a cumulative GPA 3.3
  • Undergraduate Presidential Honor’s Scholarship requires a cumulative GPA 3.5
  • Minimum Cumulative GPA for graduate students is 3.0
  • Minimum Cumulative GPA for graduate MAEd students is 3.25

   

• Quantitative Measure of Progress

  The quantitative requirement contains two components, (1) Pace of Progression and (2) Maximum Timeframe.

  1. Pace of Progression/Completion Rate

     The credit hour completion rate reflects the pace at which students must progress to ensure that they are able to complete their degree program within the maximum timeframe. The pace of progression is calculated by dividing the cumulative number of hours the student has successfully earned by the cumulative number of hours the student has attempted. All students regardless of classification must earn 67% of all hours attempted. This is a cumulative calculation and includes credits attempted at all schools before and while attending Concordia.

  2. Maximum Timeframe

     The maximum timeframe for undergraduate students to complete their degree cannot exceed 150% of the published length of the academic program. Hours are counted starting with the semester the student entered school, even those semesters in which he/she did not receive financial aid. The maximum timeframes are listed below:

     • Bachelor Degree’s 180 or 192 Hours Attempted
     • Graduate Degree’s Hours Attempted required for program

      

     Hours Attempted: Hours attempted include all hours pursued in the student’s career and are counted in the maximum timeframe whether or not financial aid was received. Attempted hours also include the following: withdrawals, incompletes, failing grades, repeated coursework, and transfer credits accepted by the University.

Financial Aid Warning

Students who do not meet the SAP standards will be placed on Financial Aid WARNING. While on WARNING status, students will continue to receive financial aid. All students who are notified of their WARNING status should seek academic counseling and take advantage of all other student services available to ensure student success at the university.

Financial Aid Termination

Students who do not meet the SAP standards for more than one term will be PROHIBITED from receiving all financial aid. Being on PROBATION status does not prohibit a student from continuing their education. Students who have lost their financial aid eligibility may be reinstated once they demonstrate satisfactory academic progress.

Appeal Standards

Only appeals for the following reasons will be accepted:

• A death of an immediate family member of the student.
• Medical/hospitalization of the student.
• Mitigating circumstances beyond the student’s control that affected their academic progress

Appeal Process

All appeals must be submitted in writing, and include the Financial Aid Satisfactory Academic Progress (SAP) Appeal Form, with supporting documentation attached, to the Financial Aid Office. Acceptable documentation for each circumstance must be stated in the appeal letter and supporting documentation must be attached, such as medical records, death certificates and any documentation that supports the student’s mitigating circumstances. The Director of Financial Aid will approve or deny appeals as they are submitted. Results of an appeal will be sent to the student in writing. Any student whose appeal is denied by the Director of Financial Aid has the right to appeal to the Financial Aid Committee. The Financial Aid Committee will use the same criteria in rendering its decision.

Appeal Decision

If a student’s appeal is approved:

• The student will be placed on PROBATION. A student on PROBATION will continue to be eligible for financial aid on a semester by semester basis provided they meet the required terms and conditions as indicated in the student’s approval. Failure to meet these requirements on a term by term basis will result in TERMINATION of financial aid.

If a student’s appeal is denied:

• The student must meet SAP standards before any further financial aid may be awarded as long as the student hasn’t reached the maximum units.

Reinstatement of Financial Aid

To reinstate financial aid a student must have an approved Financial Aid Appeal or must meet the financial aid satisfactory academic progress cumulative qualitative, quantitative, and maximum timeframe standards. Neither paying for classes out of pocket, nor sitting out a period of time is sufficient in and of itself to re-establish a student’s financial aid eligibility.

Treatment of Grades:

• Courses for which a student receives a letter grade of A, B, C, D, P or CR are included in the calculation of cumulative credit completion percentage as courses successfully completed.
• Courses for which a student receives a letter grade of IP, I, N, NP, IF, F, W or GD will be treated as credits attempted but not successfully completed.

Withdrawals:

Credits for which a grade of “W” is received are considered attempted credits but not successfully completed credits. A grade of “W” does not impact GPA but does negatively impact the cumulative completion percentage and counts toward the maximum time frame.

Repeated Coursework:

Undergraduate students are allowed to repeat a course as often as allowed by the academic policies of the university. Students are allowed to repeat a previously passed course and have it count toward enrollment for financial aid eligibility only once. However, all repeats count against the maximum timeframe (total attempted credits) and reduce the pace/completion rate because they count as earned credits only once.

Transfer Credits:

Transfer credits accepted by the institution and applied toward a student’s degree, diploma, or certificate requirements to graduate will apply toward the maximum time frame calculation. If at the point of admission a transfer students prior academic record does not meet the colleges minimum cumulative qualitative or quantitative SAP standards, the university may immediately place the student in a probation status for financial aid eligibility.

Consortium Credits:

Credits for which financial aid is received under a consortium agreement will be included in the calculation of cumulative GPA, completion percentage, and maximum time frame.

Audited Courses:

Audited courses will not be funded by financial aid and are not included in any financial aid satisfactory academic progress measurements.

Students are required to report all resources known or expected to be available to them during the period for which they seek financial assistance. These resources include, but are not limited to: veterans’ benefits, scholarships, fellowships, stipends, and unemployment earnings (including spouse’s, where applicable). Failure to report these resources can result in delays in receiving aid funds for which the student may be eligible, cancellation of the award, or even the return of funds already received.

Should any new resources become available, the student is required to report this fact. Withholding or concealing information about these resources may constitute fraud, as the student would be receiving financial aid to which he or she is not entitled.

Each year a number of financial aid recipients are distressed to learn that their aid package is being reduced due to an over-award. As required, students must inform the Financial Aid Office of any outside aid awards or changes in their class load. This will save the frustration and inconvenience that may result from an over-award.

A student’s budget, as determined by the university using federal and state calculations, could reduce the total aid package. All institutional aid is subject to coordination with federal, state, and all other aid sources. All institutional aid is subject to the policies printed in the catalog and any other printed materials. Availability of all aid is subject to federal, state, institutional, and private funding.

If a student fails to officially withdraw and receives all F’s as grades for the semester, the Department of Education considers the student to have unofficially withdrawn from classes. The university is required to investigate and determine when the student actually last attended class and then perform the required R2T4 calculation. If the date of withdrawal cannot be confirmed, the R2T4 calculation is done using a 50 percent completion rate. This process is usually completed well after the end of the semester, once grades are submitted.

The U.S. Department of Education has established new regulations to prevent fraud and abuse in the Federal Pell Grant Program or Direct Loans by identifying students with unusual enrollment histories. Some students who have an unusual enrollment history (UEH) have legitimate reasons for their enrollment at multiple institutions. However, such an enrollment history requires our office to review your file in order to determine future federal financial aid eligibility. If selected by the Department of Education (via the FAFSA), this must be resolved before you will receive financial aid.

Flags “2” and “3” require that the current institution review the student’s enrollment history to determine aid eligibility. The Financial Aid Office, in the process of reviewing a student’s UEH flag, will check the National Student Loan Data System (NSLDS) for complete enrollment history (i.e., name of each school attended during the past four academic years, dates of attendance, and aid received).

How to Resolve

All students with UEH flag 3 and some students with UEH flag 2 will be required to submit their Official/Unofficial Academic Transcripts from all colleges and universities attended during the review period. The Financial Aid Office will review all transcripts and all supporting documentation to determine if the student is eligible for federal student aid at Concordia University.

Decisions to approve or deny Unusual Enrollment History flags will be made by the Financial Aid Office based on:

• Documentation of the extent and severity of the mitigating circumstance(s) that resulted in the failure to earn academic credit.
• Adequacy of the resolution or planned resolution of the above circumstance(s).

Appealing the Ineligibility Determination

If a student has been determined by Concordia University to be ineligible for federal student aid on the basis of (or lack of) documentation, he/she may resubmit additional documentation for reconsideration.

Regaining Federal Student Aid Eligibility

Students whose aid eligibility is denied as a result of their UEH can be re-considered for federal student aid after meeting with an academic advisor and successfully completing a successful term required by their program. Successful completion is defined as a grade of C or better. Grades below C, Incompletes, and withdrawals are not considered successful completion. Students must also meet the University’s standards of Satisfactory Academic Progress (SAP).

The Higher Education Opportunity Act of 2008 (HEOA) requires institutions of higher education to establish and follow a Code of Conduct with respect to student loans that prohibits conflicts of interest for any financial aid professional [HEOA § 487(a)(25)]. Concordia University is an eligible institution under the Federal Insured Student Loan Program.

In accordance with this requirement, the Office of Financial Aid at Concordia University has issued the following conflict of interest policy and code of conduct.

1. Purpose
   The purpose of this policy is to prohibit conflicts of interest in situations involving student financial aid and to establish standards of conduct for employees with responsibility for student financial aid.
2. Applicability
   This Policy applies to all employees who work in the Office of Financial Aid and all other college employees who have responsibilities related to education loans or other forms of student financial aid. Agents of the College with responsibility for education loans or other student financial aid are also expected to abide by the terms of this Policy.
3. Definitions
   1. Conflict of Interest: A conflict of interest exists when an employee’s financial interests or other opportunities for personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the employee performs his/her responsibilities at the College.
   2. Gift: Any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimis amount. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred. The term “gift” does not include any of the following:
      1. Standard materials, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
      2. Training or informational material furnished to the College as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of educational loans to the College, if such training contributes to the professional development of the College’s employees.
      3. Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the College or an employee who is the parent of a student if such terms, conditions, or benefits are comparable to those provided to all students of the College and are not provided because of the student’s or parent’s employment with the College.
      4. Entrance and exit counseling services provided to borrowers to meet the College’s responsibilities for entrance and exit counseling under federal law, so long as the College’s employees are in control of the counseling, and such counseling does not promote the products or services of any specific lender.
      5. Philanthropic contributions to an institution from a lender, servicer, or guarantor of education loans that are unrelated to education loans or any contribution from any lender, guarantor, or servicer that is not made in exchange for any advantage related to education loans.
      6. State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
   3. Opportunity pool loan: A private education loan made by a lender to a student attending the College or the family member of such a student that involves a payment, directly or indirectly, by the College of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family.
   4. Revenue-sharing arrangement: An arrangement between the College and a lender under which (a) a lender provides or issues a loan to students attending the College or to their families; and (b) the College recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other materials benefits, including revenue or profit sharing, to the College or its employees.
4. Institutional Policy Regarding Education Loans and Student Financial Aid
   1. Revenue-Sharing Arrangements
      The College or any agent of the college will not enter into any revenue-sharing arrangement with any lender.
   2. Interaction with Borrowers
      When participating in the Federal Family Education Loan Program (FFELP), the College will not assign a first-time borrower’s federal loan, through award packaging or other methods, to a particular lender. The College will not refuse to certify, or delay certification of, any federal loan based on the borrower’s selection or a particular lender or guaranty agency. When participating in the Federal Direct Loan Program, the College may assign a first time borrower’s federal loan to the Federal Government as the lender. Under no circumstances will the College assign a student’s private student loan to a particular lender, or refuse to certify or delay certification of any private loan, based upon the borrower’s selection of lender or guaranty agency.
   3. Private Loans
      The College will 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 College providing concessions or promises regarding providing the lender with (i) a specified number of federal loans; (ii) a specified federal loan volume; or (iii) a preferred lender arrangement for federal loans.
   4. Co-Branding
      The College will not permit a private educational lender to use the College’s name, emblem, mascot, logo, or any other words, pictures, or symbols associated with the College to imply endorsement of private educational loans by that lender.
   5. Staffing Assistance
      The College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Nothing in this section, however, prevents the College from accepting assistance from a lender related to (i) professional development training for its staff; (ii) providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or (iii) staffing services on a short-term, nonrecurring basis to assist the College with financial aid-related functions during emergencies, including State-declared or federally-declared natural disasters, federally-declared national disasters, and other localized disasters and emergencies identified by the Secretary of Education.
5. Code of Conduct
   1. Conflicts of Interest
      1. No employee shall have a conflict of interest with respect to any education loan or other student financial aid for which the employee has responsibility.
      2. No employee may process any transaction related to his/her own personal financial aid eligibility or that of a relative.
   2. Gifts
      No employee may accept any gift from a lender, guarantor, or servicer of education loans. A gift to a family member of an employee or to any other individual based on that individual’s relationship with the employee shall be considered a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and the employee has reason to believe the gift was given because of the employee’s position at the College.
      Token awards from professional associations (state, regional, or national) that recognize professional milestones or extraordinary service to parents and students, or scholarships for conference attendance or other professional development opportunities, may be accepted.
   3. Prohibited Contracting Arrangements
      No employee shall 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.
   4. Advisory Board Compensation
      No employee who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors may receive anything of value from the lender, guarantor, or group of lenders or guarantors in return for that service.
   5. Reimbursement of Expenses
      Expenses incurred while attending professional association meetings, conferences, or in connection with service on an advisory board, commission, or group described in Section V.D. of this Policy must be paid by the College. Entertainment expenses such as concert or sports tickets or greens fees may not be accepted. Employees are expected to personally pay for such expenses or request reimbursement from the College in accordance with College policy.
   6. Meals
      Employees may occasionally need to share meals with employees of lenders, guaranty agencies, the State of California, or other colleges or universities in the course of business. Meals offered as a part of meetings, conferences, or other events may be accepted if all participants in the meeting or event are offered the meals or if the meals are included as a part of a registration fee.
6. Policy Violations
   Violations of this Policy may result in disciplinary action, up to and including dismissal.
7. History
   This Policy was developed based on the Statement of Ethical Principles and Code of Conduct adopted by the National Association of Student Financial Aid Administrators (NASFAA).