Hobart and William Smith Colleges

Code of Conduct

Background

Hobart and William Smith Colleges’ Code of Conduct was developed as a best practice and to fulfill the requirements of the Higher Education Act of 1965 amended by the Higher Education Opportunity Act of 2008 even though we do not make preferred lender recommendations. Our Code of Conduct is designed to create and ensure uniform student loan practices that focus on the best interest of borrowers and serves as a reminder to our families that they are free to select a lender of their choice.

Revenue Sharing

Hobart and William Smith Colleges (“the Colleges”) and any of its affiliates or Colleges’ related organizations shall not accept or receive anything of value from any entity involved in the making, holding, consolidating, servicing, guaranteeing or processing of any student loans (“Lending Institution”) in exchange for favorable consideration by the Colleges, including, but not limited to, designation of the Lending Institution on its preferred or approved lender list. Designation on the Colleges’ lender list, preferred or otherwise, shall be the result of compliance with the Colleges’ established guidelines.

Gift and Trip Prohibition

Colleges’ employees with responsibilities involving student financial aid, including administrative/executive officials with decision-making authority over financial aid operations, are prohibited from soliciting and/or receiving gifts of more than nominal value and/or trips from any Lending Institution.

Advisory Board Membership

Colleges’ employees with responsibilities involving student financial aid, including administrative/executive officials with decision-making authority over financial aid operations, who serve on an advisory board, commission, or group established by a Lending Institution or group of Lending Institutions are prohibited from receiving anything of value from the Lending Institution or group, except that the employees may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.

Financial Benefit

Colleges’ employees with responsibilities involving student financial aid, including administrative/executive officials with decision-making authority over financial aid operations, shall not 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 Lending Institution or on behalf of a Lending Institution relating to education loans.

Selection of Lender

1. For any first time borrowers, the Colleges will not assign, through award packaging or other methods, the borrower’s loan to a particular Lending Institution.

2. The Colleges will not refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular Lending Institution.

3. The Colleges will clearly indicate that students have the right and ability to select the lender of their choice regardless of any lender list.

4. The Colleges will not request or accept any offer of funds from any Lending Institution to be used for private education loans, including funds for an opportunity pool loan, in exchange for providing the Lending Institution with:

a specified number of loans made, insured, or guaranteed;
a specified loan volume of such loans; or
a preferred lender arrangement for such loans.

Call Center Prohibition

The Colleges prohibit employees of Lending Institutions from serving as representatives of the Colleges or otherwise assisting with call center staffing or financial aid office staffing.

Lender Guidelines

The Colleges will develop, publish and enforce lender guidelines which shall establish the criteria for inclusion or designation as a preferred or approved lender and the process by which financial institutions will be selected for student loan program participation. Selection of Lending Institutions for inclusion on a preferred lender list shall be based upon the best interests of students and their parents, without regard to the financial interests of the Colleges. Nothing in the guidelines shall impair the right of the student to select the lender of their choice. These guidelines will be periodically reviewed, revised, as necessary, and published.

Publication and Notice of Code of Conduct

This Code of Conduct must be published prominently on the Colleges’ website. In addition, at a minimum, Colleges’ employees with responsibilities involving student financial aid, including administrative/executive officials with decision-making authority over financial aid operations, must be informed of the provisions of the Code of Conduct on an annual basis.

Sanctions

Any Colleges’ employee who violates this Code of Conduct may be subject to discipline, up to and including termination of employment.

Contact

If you have any questions regarding the financial aid process, please contact the Office of Financial Aid at:

Phone: (315) 781-3315
Fax: (315) 781-4048
Email: finaid@hws.edu

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Financial Aid