UNT Code of Conduct for Financial Aid Professionals

In order to prevent any conflicts of interest in the administration of programs for Federal Student Assistance, the University of North Texas ("UNT") has adopted a Code of Conduct for Financial Aid Professionals. The Code of Conduct specifically applies to:

  • All officers or employees of the University of North Texas who are employed in the Office of Student Financial Aid and Scholarships;
  • All officers or employees of the University of North Texas who otherwise have responsibilities with respect to educational loans; and
  • All agents of the University of North Texas who have responsibilities with respect to educational loans.

Individuals who are subject to this Code of Conduct (hereinafter "officers, employees, and agents") must conduct themselves in accordance with the UNT Ethics Policy (05.015) and the standards set out below:

  1. Gifts. No officer, employee or agent shall solicit or accept any gift from a lender, guarantor or servicer of educational loans.
    1. "Gifts" include:
      • Any gratuity, favor, discount, entertainment, hospitality, loan, or other item in excess of $50.
      • Any gift of service, transportation, lodging or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.
      • Any gifts to family members or any other individual based on the individual's relationship with the officer, employee or agent if: (i) the gift was given with the knowledge and acquiescence of the officer, employee or agent and (ii) the officer, employee or agent had reason to believe the gift was given because of her or his official position.
    2. "Gifts" do not include:
      • Standard material, activities, or programs related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
      • Food, refreshments, training, or informational material furnished to an officer, employee or agent, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to UNT, if such training contributes to the professional development of the officer, employee, or agent.
      • Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by UNT if such terms, conditions, or benefits are comparable to those provided to all students of UNT.
      • Entrance and exit counseling services provided to borrowers to meet UNT’s responsibilities for entrance and exit counseling as long as UNT’s staff is in control of the counseling and specific lender's products and services are not promoted.
      • Philanthropic contributions to UNT 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.
      • State education grants, scholarships, or financial aid funds administered by or on behalf of a state.
  2. Stock Ownership. A person employed by the University of North Texas in the Office of Student Financial Aid and Scholarships may not own stock or hold another ownership interest in a student loan lender, other than through ownership of shares in a publicly traded mutual fund or similar investment vehicle in which the person does not exercise any discretion regarding the investment of the assets of the fund or other investment vehicle. For the purposes of this section a "student loan lender" means a person whose primary business is: (a) making, brokering, arranging, or accepting applications for student loans; or (b) a combination of activities described in subsection (a).
  3. Contracting Agreements. No officer, employee or agent 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. This provision does not prohibit:
    • an officer or employee who is not employed by the UNT Office of Student Financial Aid and Scholarships and who does not otherwise have responsibility with respect to educational loans or an agent who does not have responsibility with respect to educational loans from performing paid or unpaid service on a board of a lender, guarantor or servicer of education loans as may be consistent with other university policy.
    • an officer or employee who is not employed by the UNT Office of Student Financial Aid and Scholarships but who has responsibility with respect to educational loans as a result of a position held at the institution, or an agent who has responsibility with respect to educational loans, from performing paid or unpaid service on a board of directors of a lender, guarantor, or servicer of education loans, in accordance with university ethics and dual employment policies.
    • an officer, employee, or contractor of a lender, guarantor, or servicer of education loans from serving on the Board of Regents consistent with Regents Rules relating to Board Ethics and Standards of Conduct.
  4. Advisory Board Compensation. No officer, employee or agent who serves on an advisory board, commission or group established by a lender, guarantor or group of lenders or guarantors shall receive anything of value from the lender, guarantor or group of guarantors other than the reimbursement of reasonable expenses incurred in service to such an advisory board, commission or group.
  5. Agreements and Practices. No officer, employee or agent of the University of North Texas may enter into the following types of agreements or engage in the following practices:

    In addition officers, employees or agents of the University of North Texas may not enter into nor engage in the following:

    1. revenue-sharing arrangement with any lender.
    2. assign any first-time borrower’s loan, through award packaging or other method, to a particular lender or refuse to certify or delay certification of, any loan based on the borrower's selection of a particular lender or guarantee agency.
    3. 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 university providing concessions or promises regarding providing the lender with:
      • a specified number of loans made, insured or guaranteed; or,
      • a specified loan volume; or,
      • a preferred lender arrangement.
    4. request or accept from any lender any assistance with call center staff or financial aid office staffing except in regard to:
      • professional development training for financial aid administrators;
      • providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that the materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or
      • staffing services on a short-term non-recurring basis to assist the institution with financial aid related functions during emergencies.

In addition to the above statements, all financial aid 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.