Code of Conduct
The Code of Conduct policy sets forth the University’s commitment to administer financial aid free from conflicts of interest and in compliance with applicable laws.
This policy is applicable to all officers, employees and agents of the University, including without limitation individuals who are employed in the Office of Student Financial Aid or who otherwise have responsibilities with respect to education loans.
The University of Kansas Lawrence Campus Office of Student Financial Aid (OSFA) and the University of Kansas Medical Center Student Financial Aid Office (SFAO) serve students, families, and the community by providing financial aid information and resources to assist students in achieving their educational goals.
The University is committed to providing quality financial aid services to its constituents while maintaining equality and accountability in the administration of public, institutional and private financial aid funds.
To ensure trust in the University’s administration of financial resources to help students fund their education, all officers, employees and agents of the University, including without limitation individuals who are employed in the OSFA/SFAO or who otherwise have responsibilities with respect to education loans, are required to abide by the following code of conduct.
- The University shall not enter into any revenue sharing arrangements with a lender. Revenue sharing is any arrangement in which a lender pays a fee or provides other material benefits, including revenue or profit sharing, to the University or to its officers, employees or agents, in exchange for recommending the lender or the loan products of the lender.
- No officer or employee of the OSFA/SFAO (or an employee or agent who otherwise has responsibilities with respect to education loans) shall solicit or accept gifts from a lender, guarantor or servicer of education loans. For purposes of this policy, a gift to a family member of an officer or employee or to any other individual based on that individual’s relationship with the officer or employee, shall be considered a gift to the officer or employee if the gift is given with the knowledge and acquiescence of the officer or employee and the officer or employee has reason to believe the gift was given because of the official position of the officer or employee.
- No officer or employee of the OSFA/SFAO (or employee or agent who otherwise has responsibilities with respect to education loans) shall accept from a lender, or an affiliate of any lender, any fee, payment or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
- An officer or employee who is not employed in the OSFA/SFAO but who has responsibility with respect to education loans as a result of his or her position held at the University, or an agent who has responsibility with respect to education loans, shall not be prohibited from performing paid or unpaid service on a board of directors of a lender, guarantor, or servicer of education loans, provided that such officer, employee or agent recuses his/herself from participating in any decision of the board with regard to education loans at the University and otherwise complies with applicable Kansas ethics statutes.
- The University shall not assign, through the award packaging or other methods, a first-time borrower’s loan to a particular private lender. In addition, the University shall not refuse to certify, or delay the certification, of any loan based on the borrower’s selection of a particular lender or guaranty.
- The University shall not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of federal loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement.
- The University shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training consistent with state governmental ethics statutes, educational counseling materials (as long as the materials identify the lender that assisted in preparing the materials) and staffing services on a short-term, nonrecurring basis during emergencies or disasters. Employees of lenders must be directed to identify themselves as employees of the lender and to never identify themselves as University employees when meeting or speaking with students or parents.
- No employee of the OSFA/SFAO (or any employee who otherwise has responsibilities with respect to education loans or financial aid) shall receive anything of value for serving on an advisory board, commission or group established by a lender or guarantor (or a group of lenders or guarantors).
- The OSFA/SFAO shall:
- provide student and parent borrowers with access to, and process loans for, all lenders of choice, including those not on a ‘lender list’
- offer the maximum federal aid eligibility and recommend that borrowers explore the benefits of federal financial aid before processing private/alternative loans
- provide ‘exit counseling’ to educate borrowers on their rights and responsibilities and provide information to enable them to determine which repayment option best fits their individual financial needs
- provide comprehensive financial aid counseling for students, prospective students, families and the community
- The OSFA/SFAO shall communicate to its constituents:
- established priority dates, deadlines, and eligibility criteria via its website, email, publications, and presentation
- the need to complete and submit required documents in a timely manner via email and the University’s student information system (Enroll & Pay)
- information regarding relationships with lenders and the criteria and process used to select lenders on any lender lists
- the right and ability of borrowers to select a lender of their choice regardless of any lender list
Violations of this policy may result in disciplinary action, up to and including dismissal of employees, or termination of agent relationships.
Higher Education Opportunity Act (Public Law 110-315) K.S.A. § 46-237 (gifts to employees) K.S.A. 46-233 (contracts involving state officer or employee; prohibited acts)
- A gift is defined as any gratuity, favor, discount, entertainment, hospitality, loan or other item having monetary value of more than a de minimus amount. However, a gift does not include (1) a brochure, workshop or training using standard materials relating to a loan, default aversion or financial literacy, such as a brochure, workshop or training; (2) food, training or informational material provided as part of a training session designed to improve the service of a lender, guarantor or servicer if the training contributes to the professional development of the University’s officer, employee or agent and attendance is authorized by the University; (3) favorable terms and benefits on an education loan provided to a student employed by the University if those terms and benefits are comparable to those provided to all students at the institution; (4) entrance and exit counseling as long as the University’s staff are in control of the counseling and the counseling does not promote the services of a specific lender; (5) philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans or any contribution that is not made in exchange for advantage related to education loans, and; (6) state education grants, scholarships or financial aid funds administered by or on behalf of a state.
- 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, directly or indirectly, by the University of points, premiums, additional interest or financial support to the lender for extending credit to the student or family.
Family Education Rights and Privacy Act (FERPA)
The University of Kansas protects the privacy of its students’ education records in compliance with the federal Family Educational Rights and Privacy Act (FERPA) and its implementing regulations. FERPA and KU’s Student Records Policy also provide students the right to inspect and review their educational records.
Responsible Office: Office of the Provost
Office of the Provost
1450 Jayhawk Blvd., Room 250
Lawrence, Kan. 66045
Office of the Executive Vice Chancellor
2032 Murphy Building, Mailstop 2015
3901 Rainbow Blvd.
Kansas City, Kan. 66160
Office of the Vice Provost for Student Success
1450 Jayhawk Blvd., Room 133
Lawrence, Kan. 66045
Vice Chancellor for Academic and Student Affairs
5015 Wescoe Pavilion, Mailstop 1040
3901 Rainbow Blvd.
Kansas City, Kan. 66160
KU Lawrence Campus
Office of Student Financial Aid
50 Strong Hall
1450 Jayhawk Blvd.
Lawrence, Kan. 66045-7535
KU Medical Center
Student Financial Aid Office
G035 Dykes Library
3901 Rainbow Boulevard, Mailstop 4005
Kansas City, Kan. 66160