Student Loan Code of Conduct (III.A.3)

Volume III: Ethics
Chapter A: Conduct
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Office of the Vice President for Ethics and Compliance
Date Issued: June 15, 2020
Date Last Revised: January 2, 2024

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

Contacts

Policy Clarification

Vice President for Ethics and Compliance
765-494-5830 | vpec@purdue.edu

Campus Specific Questions

Fort Wayne: Director of Financial Aid
216-481-6820 | finaid@pfw.edu

Northwest: Director of Financial Aid
219-989-2301 | finaid@pnw.edu

West Lafayette: Executive Director, Division of Financial Aid
765-494-5090 | facontact@purdue.edu

Statement of Policy

This policy establishes Purdue University’s Student Loan Code of Conduct as follows:

Purdue officers and employees, and Purdue Agents, are prohibited from having a Conflict of Interest with respect to any Student Loan.
Purdue does not enter into any Prohibited Revenue Sharing Arrangement with any lender.
Officers and employees who are employed in any Purdue financial aid office or who otherwise have responsibilities with respect to Student Loans, and Purdue Agents with such responsibilities, may not ask for or accept any Prohibited Gift from any lender, guarantor, or servicer of Student Loans.
Officers and employees who are employed in any Purdue financial aid office or who otherwise have responsibilities with respect to Student Loans, and Purdue Agents with such responsibilities, may not enter into any Prohibited Contracting Arrangement.
Purdue does not (i) assign, through award packaging or other methods, a Student Loan of a first time borrower to a particular lender, or (ii) refuse to certify, or delay the certification of, any Student Loan, based on a borrower’s selection of a particular lender or guaranty agency.
Purdue does not request or accept from any lender any offer of funds for private education loans (as defined in the federal Truth in Lending Act) to students, including funds for an opportunity pool loan, in exchange for any commitment by the University (i) to provide the lender with a specified number or volume of Student Loans, or (ii) to enter into a preferred lender arrangement for such loans.
Purdue does not ask for or accept any Prohibited Staffing Assistance from any lender.
Officers and employees who are employed in any Purdue financial aid office or who otherwise have responsibilities with respect to Student Loans or other Purdue student financial aid may not ask for or accept any Prohibited Advisory Board Compensation.

Reason for This Policy

This Policy is established (i) to ensure that Purdue officers and employees and Purdue Agents will administer all Student Loan programs in an honest, ethical, and legal manner, and (ii) to satisfy the requirements imposed by the HEOA on Purdue as a participant in federal loan programs to establish and administer a Student Loan Code of Conduct meeting the requirements of the HEOA.

Individuals and Entities Affected

All Purdue faculty, staff, and students; Purdue Agents involved in or with responsibility for any aspect of any federal student loan program or with student financial aid; and Human Resources.

Exclusions

There are not exclusions to this policy.

Responsibilities

Compliance Officer

Interpret this policy and establish mechanisms and procedures to promote overall compliance with this policy.
Develop procedures to ensure that each officer, employee, and Purdue Agent with any responsibility with respect to Student Loans is informed about the provisions in this Student Loan Code of Conduct (i) when the person or entity first assumes responsibility, and (ii) at least annually thereafter for as long as the person or entity retains responsibility.

DFA

Identify those officers, employees, and Purdue Agents on their campus who need to comply with this policy and take steps to ensure that those individuals or entities certify their compliance (i) when they first assumes duties or responsibilities covered by this policy, and (ii) no later than June 15 each year thereafter for as long as they retain duties or responsibilities covered by this policy.
Notify the Compliance Officer of the completed certification process no later than June 30 each year.
Coordinate efforts to ensure certifications of compliance are recorded and retained in accordance with the HEOA.

Purdue Officers and Employees and Purdue Agents

Those involved in or with responsibility for any aspect of any federal student loan program or with student financial aid must familiar themselves and comply with this policy to the extent applicable to their duties and responsibilities and certify such compliance upon the request of a DFA.
If uncertain whether any particular matter falls within or is governed by any of the provisions of this policy, disclose all relevant facts and circumstances to the Compliance Officer and obtain written approval before proceeding.

Definitions

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

Compliance Officer
The Vice President for Ethics and Compliance or a Purdue officer or designee who has the primary responsibility for administering this policy.

Conflict of Interest
A situation where the Financial Interest of an officer, employee, or Purdue Agent compromises, or could appear to compromise, their judgment or ability to carry out responsibilities associated with Student Loans. A Conflict of Interest may take many forms, but in general arises when an officer, employee, or Purdue Agent in a relationship with an outside person or organization is in a position to influence the University’s administration of Student Loans or other financial aid in ways that could lead directly or indirectly to financial gain for the officer, employee, or Purdue Agent, or their Dependents.

Dependent
An officer’s, employee’s, or Purdue Agent’s (including individual owners, officers, and employees of a Purdue Agent that is a legal entity) spouse or unemancipated children (including stepchildren and adoptees) under the age of 18, or anyone more than one-half of whose support is provided during a year by an officer, employee, or Purdue Agent (including individual owners, officers, and employees of a Purdue Agent that is a legal entity).

DFA
The Executive Director of Financial Aid on the West Lafayette campus and the Purdue employee with analogous responsibilities for financial aid programs on each Purdue Regional Campus.

Financial Interest
Any interest that will, could, or is intended to, lead to a profit or an ascertainable increase in the income or net worth of an officer, employee, Purdue Agent, and/or a Dependent. The profit or increase in income or net worth could be realized through the receipt of anything of monetary value.

HEOA
The federal Higher Education Opportunity Act, Public Law 110-315.

Prohibited Advisory Board Compensation
Compensation or anything of value paid or provided in return for service on an advisory board, commission, or group established by a lender or guarantor, or by a group of lenders or guarantors, of Student Loans. The term does not include reimbursement for reasonable expenses incurred in serving on such a board, commission, or group.

Prohibited Contracting Arrangement
Any contract or other arrangement involving the payment by a Student Loan lender, or the affiliate of any Student Loan lender, of any fee 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 or on behalf of a lender relating to Student Loans, unless the Compliance Officer provides written confirmation that a proposed contract or arrangement is permitted by the HEOA following full disclosure of the facts and circumstances related to the proposed arrangement.

Prohibited Gift
Any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount by a lender, guarantor, or servicer of Student Loans to (i) a Purdue officer, a Purdue employee, or a Purdue Agent, or (ii) a family member of such officer, employee or agent (including a family member of an owner, officer, or employee of a Purdue Agent that is a legal entity), if the officer, employee or agent (a) knows of and acquiesces in the gift, and (b) has reason to believe that the gift was given because of their position. The term “Prohibited Gift” includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after an expense has been incurred.

The term “Prohibited Gift” does not include (i) standard materials, activities, or programs such as brochures, workshops, or training on issues related to loans, default aversion or preventions, or financial literacy, (ii) food, refreshments, training, or informational materials contributing to the professional development of an officer, employee, or Purdue Agent that are provided as an integral part of a training session designed to improve the services of a lender, guarantor, or servicer of Student Loans to Purdue, (iii) favorable terms, conditions, and benefits on a Student Loan provided to a student employed by Purdue if the same terms, conditions, and benefits are provided to all Purdue students, (iv) entrance and exit counseling services provided to borrowers when Purdue’s staff are in control of the counseling and the counseling does not promote the products or services of any specific lender, (v) philanthropic contributions to Purdue from a lender, guarantor, or servicer of Student Loans that are unrelated to Student Loans, or any contributions from a lender, guarantor, or servicer that are not made in exchange for any advantage related to Student Loans, or (vi) education grants, scholarships, or financial aid funds administered by or on behalf of a state.

Prohibited Revenue Sharing Arrangement
An arrangement between the University and a lender under which (i) the lender would provide or issue a Student Loan to Purdue students or their families, and (ii) Purdue would recommend the lender or its loan products, and in exchange, the lender would pay any fee or provide any other material benefits, including revenue or profit sharing, to Purdue, to a Purdue officer or employee, or to a Purdue Agent.

Prohibited Staffing Assistance
Any assistance from any lender with respect to staffing of any Purdue call center or financial aid office, unless the Compliance Officer provides written confirmation that proposed staffing assistance is permitted by the HEOA following full disclosure of the facts and circumstances related to the proposed assistance.

Purdue Agent
Any person or entity legally authorized by the University to act on Purdue’s behalf with respect to Student Loans.

Student Loan(s)
A loan or loans offered under any federal education loan program.

Website Address for This Policy

www.purdue.edu/vpec/policies/ethics/iiia3

History and Updates

January 2, 2024: Removed definitions for Certificate of Acknowledgement and Certificate of Compliance and aligned responsibilities with electronic process.

November 18, 2011: Policy number changed to III.A.3 (formerly X.1.1).

June 15, 2009: This is the first University policy establishing a Student Loan Code of Conduct for compliance with the HEOA.

Appendix

There are no appendices to this policy.