This is the Manhattan School of Music code of conduct for financial aid professionals.
The purpose of this policy is to prohibit conflicts of interest in situations involving student financial aid and to establish standards of conduct for Manhattan School of Music officers, employees, and agents with responsibility for student financial aid.
This Policy applies to all employees who work in the Office of Financial Aid and all other College officers, employees, and agents who have responsibilities related to education loans or other forms of student financial aid.
A. Conflict of Interest: A conflict of interest exists when an employee’s financial interests or other opportunities for personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the employee performs his/her responsibilities at MSM.
B. Gift: Any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred. The term “gift” does not include any of the following:
C. Opportunity pool loan: A private education loan made by a lender to a student attending MSM or the family member of such a student that involves a payment, directly or indirectly, by MSM of points, premiums, additional interest, or financial support to such lender for the purpose of such lender extending credit to the student or the family.
D. Revenue-sharing arrangement: An arrangement between MSM and a lender under which (a) a lender provides or issues a loan to students attending MSM or to their families; and (b) MSM recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other materials benefits, including revenue or profit sharing, to MSM or its employees.
A. Revenue-Sharing Arrangements
The College will not enter into any revenue-sharing arrangement with any lender.
B. Interaction with Borrowers
When participating in the Federal Direct Loan program, the College will not assign a first-time borrower’s federal loan, through award packaging or other methods, to a particular lender. The College will not refuse to certify, or delay certification of, any federal loan based on the borrower’s selection or a particular lender or guaranty agency. When participating in the Federal Direct Loan program, the College may assign a first time borrower’s federal loan to the Federal Government as the lender.
C. Private Loans
Under no circumstances will the College assign a student’s private student loan to a particular lender, or refuse to certify or delay certification of any private loan, based upon the borrower’s selection of lender or guaranty agency. The College will not 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 College providing concessions or promises regarding providing the lender with (i) a specified number of federal loans; (ii) a specified federal loan volume; or (iii) a preferred lender arrangement for federal loans.
The College will not permit a private educational lender to use the College’s name, emblem, mascot, logo, or any other words, pictures, or symbols associated with the College to imply endorsement of private educational loans by that lender.
E. Staffing Assistance
The College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Nothing in this section, however, prevents the College from accepting assistance from a lender related to (i) professional development training for its staff; (ii) providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or (iii) staffing services on a short-term, nonrecurring basis to assist the College with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, federally declared national disasters, and other localized disasters and emergencies identified by the Secretary of Education.
A. Conflicts of Interest
C. Prohibited Contracting Arrangements
D. Advisory Board Compensation
E. Reimbursement of Expenses
A. Violations of this Policy may result in disciplinary action, up to and including dismissal.
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