Code of Conduct
All behavior of Providence College financial aid office employees and other employees with responsibility for educational loans shall be consistent with exemplary standards of professional conduct in the performance of their duties and consistent with this Code of Conduct. All directors, officers, employees and other representatives of the College are not only required to comply with this Code, but also to promptly inform the College’s legal counsel should they become aware of facts indicating that there may be, or may have been, a violation of this Code.
- The College maintains a suggested lender list. However, such list does not, in any way, limit the choice of lenders for our students.
- Students are given a genuine, fair and equal opportunity to choose among and between all lenders and all types of loans regardless of what is presented on our suggested lender list.
- The College does not assign for any borrower, through award packaging or other methods, a loan to a particular lender, and does not refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
- The College does not solicit or accept anything of value from any lender in exchange for any advantage sought by the lender to make educational loans to students enrolled at, or admitted to, the College.
- The College does not offer “opportunity loans,” defined as loans provided up to a specified amount to students with poor or no credit history, or to international students, whom the lender claims would otherwise not be eligible for the lender’s alternative loan program, as this type of loan may not be in the borrower’s best interest because of the associated high interest rate.
- All employees (financial aid office and other employees with responsibility for educational loans) must take reasonable and necessary steps to avoid an actual conflict of interest and the appearance of a conflict of interest, and they must comply with the College’s Conflict of Interest Policy.
- All employees (financial aid office and other employees with responsibility for educational loans) are prohibited from entering into revenue sharing relationships with lenders, and from soliciting or accepting any gift worth more than nominal value from any lender. The Department of Education defines “gift” as “any gratuity, favor, discount, entertainment, hospitality, loan or other item valued at more than a de minimus amount; the term includes services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or by reimbursement.”
- All employees (financial aid office and other employees with responsibility for educational loans) are prohibited from entering into any type of consulting arrangement or other contract to provide to a lender services relating to educational loans.
- All employees (financial aid office and other employees with responsibility for educational loans) who serve on an advisory board (or commission or group) relating to educational loans established by a lender or group of lenders are prohibited from receiving anything of value from the lender or group of lenders in connection with service on such advisory board (or commission or group); however, reimbursement for reasonable expenses by employees with responsibilities for financial assistance who sit on a lender’s advisory board (or commission or group) are permitted.
The financial aid office is prohibited from receiving staffing services from the employees, representatives, or agents of lenders.
- The College prohibits the employees, representatives, or agents of lenders from identifying themselves to College students or their parents as employees, representatives, or agents of the financial aid office.
The College prohibits lenders or guaranty agencies from using its name, logo, emblem, or mascot, or any other words, symbols, or photographs readily associated with the College, in any advertisement, publication or other communication suggesting that the College has endorsed loans or services offered or guaranteed by the guaranty agency or lender.
- All student financial information, including but not limited to information about need, resources, loans and other aid, is deemed to be confidential sensitive data and the College does not permit disclosure of such data without proper authorization or as otherwise permitted or compelled by law.
This Code of Conduct is distributed to all employees (financial aid office and other employees with responsibility for educational loans) on an annual basis.
Copies of this code are also available in the Office of Financial Aid, Harkins Hall 403, One Cunningham Square, Providence, RI, 02918.