Financial Aid Code of Conduct

Policy # Policy Name BR # BOR Action Date
5.9 Financial Aid Policy for CSCU Community Colleges 17-043 2017-03-02

Financial Aid Policy for CSCU Community Colleges

Philosophy

The Connecticut State Colleges and Universities (CSCU) system, with support from the Board of Regents, has developed an institutional packaging philosophy to ensure the consistent, fair, and equitable distribution of available funds in order to provide financial assistance to eligible students. To support the educational achievement of our students, each institution shall award financial aid funds from available resources to promote access to higher education, facilitate completion, enable personal and professional growth, and ultimately contribute to the prosperity of the State of Connecticut.

Student Assistance Provision

To assist prospective students and financial aid applicants with their decision-making process, colleges must provide timely financial aid awards. The Board of Regents recommends that colleges require students provide only information consistent with the annual requirements provided by the US Department of Education and Federal Student Aid in an effort to remove barriers to entry and place students on a path to success.

Awarding

Financial assistance is available from federal, state, and institutional sources; it is awarded to students that apply and meet certain eligibility criteria. Available funds shall be packaged based on Financial Need, as determined by federal methodology calculations resulting from completion of a Free Application for Federal Student Aid (FAFSA). Financial Need is defined as a student’s Expected Family Contribution (EFC) as compared to a Cost of Attendance (COA). Financial aid awards shall not exceed a student’s Cost of Attendance (COA). Aid eligibility which is contingent on Financial Need may be influenced by the presence of other forms of financial assistance available to students, as well as the colleges’ policies for distributing their allocated resources.

To comply with federal regulations, each applicant must meet the Satisfactory Academic Progress standard as defined in the “Satisfactory Academic Progress Policy for Student Financial Aid Recipients at CSCU Community Colleges.”

Financial aid awards are made throughout the year on a first-come, first-served basis that is subject to available funding. All students are initially awarded based on estimated full-time enrollment and fulltime costs. Applicants whose financial aid applications are complete by college-specific priority deadlines will receive maximum consideration in the distribution of funding resources and according to funding criteria. Colleges shall give special attention to those students with exceptional Financial Need.

A student’s financial aid award is subject to adjustment at any point in the academic year due to reasons including, but not limited to: a correction by the college, changes made to FAFSA information, the receipt of financial assistance from outside sources, and/or changes in federal, state, or institutional appropriations.

Financial aid funds shall be used to cover only those courses and related expenses required to complete a student’s selected course of study. Previously passed coursework may only be repeated once and be counted as credit in determining a student’s enrollment status for financial aid. A second repetition of a previously passed course may not count toward a student’s enrollment for financial aid purposes.

Disbursement

Financial aid is disbursed according to payment period, based on a student’s enrollment measured in credit hours as defined by the US Department of Education. Each traditional semester, colleges shall take a census for the purpose of determining an official enrollment status used for institutional reporting purposes, and additionally for the purpose of financial aid recalculation in preparation for disbursement. The census/recalculation date is established by the system office. Since applicants are initially awarded on the estimation of full-time enrollment, a student who is enrolled at a less than fulltime rate will have their financial aid award adjusted to reflect their official enrollment status. Disbursement amounts shall be finalized after the census date.

Financial aid disbursement is also contingent on a student’s active engagement within each registered course as defined by the US Department of Education. Students who are not actively engaged in registered courses shall have their financial aid reduced to reflect the courses in which active engagement was established.

Adopted December 20, 1999 – CC BOT; BOR revised April 6, 2017

Distribution of Information and Funding

Colleges shall maintain a responsibility to educate their students on making sound financial decisions related to paying for college and/or financing college costs. This may be achieved through embedding strategies designed to supply students with available information, which may include loan entrance/exit counseling, financial workshops, presentations, or other available resources.

The availability of federal, state, and institutional financial assistance is critical to student success efforts across our system, as it represents an investment in our students and a progressive economic impact to the State of Connecticut. Some unavoidable delays in the distribution of funding to students may occur due to student requirements toward the administration of certain financial aid programs. Colleges should exercise good judgment and care in order to mitigate any possible delay in distributing funds to students.

Therefore, the Board of Regents urges the financial aid offices within each community colleges to assign a high priority to the prompt verification and awarding of eligible financial aid applicants in order to provide assistance in recruitment efforts on behalf of the colleges and the system. Additionally, financial aid offices shall make every effort, consistent with its other essential responsibilities, to require only the information necessary to provide financial aid awards to students.

Adopted November 20, 1978 BOT; BOR Revised April 6, 2017

Financial Aid Code of Conduct
Purpose Statement

This Code of Conduct is intended to ensure that the relationships between providers of education loans and other forms of financial aid to students of the Community Colleges within the Connecticut State Colleges and Universities (CSCU) system with whom they deal are free from all conflicts of interest, both actual and perceived. The students of our community colleges or, in appropriate cases their parents, shall be the sole beneficiaries of all forms of financial aid.

I.Definitions

  1. “College” Shall mean any community college within the CSCU system, including the Board of Regents.
  2. “Lending Institution” or “Lender” shall mean any entity that itself, or through an affiliate, engages in the business of making or guaranteeing loans to students, parents or others for the purposes of financial higher education expenses. “Lending Institution” or “Lender” shall not include any community college in the CSCU system, the Board of Regents, the State of Connecticut or the Federal Government.
  3. “Compensation” shall mean anything of value, including but not limited to, money, credits, loans, discounts, payments, fees, forgiveness of principal or interest, reimbursement of expenses, charitable contributions, stock options, consulting fees, educational grants, vacations, prizes, gifts or other items of value, whether given directly or indirectly.
  4. “Trade Association” shall mean any higher education financial aid, lending or banking trade, industry, or professional association that has received compensation with the preceding 12-month period from any Lending Institution or Lender.
  5. “Outside Director” shall mean a member of a lender’s board of directors or board of trustees who receives compensation from such lender in connection with his or her service on the board of directors of board of trustees and who receives no other compensation from the lender as an officer, employee, or agent of the lender.
  6. “Agent” shall mean an employee or other person acting as a representative of and at the direction of or under the control of a college where such person’s responsibilities relate primarily to the college’s activities involving financial aid or higher education loans.
  7. “Affiliated Organization” shall mean an alumni association, booster club, foundation, athletic organization, social organization, academic organization, professional organization, or other organization which is affiliated with a college and which is not a separately existing legal entity.
  8. “Opportunity Loan” shall mean a loan to any student who, because of his/her credit history or lack of credit history, does not have access to student loans on reasonable terms.

II.Code of Conduct

  1. Prohibition of Certain Compensation to College Employees
    1. No college trustee, director, officer, or agent, including any employee who is employed in the financial aid office of a college, or who otherwise has responsibilities with respect to higher education loans or other financial aid at the college, and no spouse or dependent child of any such person (“family member”) shall accept compensation of more than nominal value (not to exceed the gift limitations established in the State Code of Ethics), directly or indirectly, from or on behalf of a lending institution or trade organization. This provision shall not be construed to prohibit any trustee, director, agent, or employee of a college or any of their family members from receiving compensation for the conduct of non-college business with any lending institution or trade organization or from accepting compensation that is offered to the general public, provided receipt of such compensation is permitted by the State Code of Ethics.
    2. Notwithstanding the prohibitions set forth in subsection II.A.1 above or any other prohibition of this Code of Conduct, (i) a college may hold a membership in any nonprofit professional organization; and (ii) a college trustee, director, officer, or employee who does not have responsibilities with respect to higher education loans or financial aid may serve as an outside director of a lending institution or trade association and receive compensation at the lending institution’s or trade association’s established compensation rates for outside directors, provided that any college trustee, director, officer, or employee service on the board of the lending institution or trade association is precluded from participating in such board’s discussions or decisions that might affect the interests of the college, and provided further that such college trustee, director, officer or employee complies with the Board of Regents Ethics Statement and receives annual written notice of this Code of Conduct and of the Board of Regents Ethics Statement.
    3. Notwithstanding the prohibitions set form in subsection II.A.1 above, a trustee, director, officer or employee of a lending institution or trade association who does not have responsibilities with respect to higher education loans or financial aid shall not be prevented from serving on the Board of Regents of CSCU solely by virtue of his or her position with the lending institution or trade association, provided that any such person is precluded from participating in the Board’s discussions or decisions that might affect the interests of such lender or trade association.
    4. Nothing in this Code of Conduct shall be construed to conflict with the requirements of Connecticut General Statutes §10a-201 et seq., including without limitation §10a-203(a), and §10a221 et seq.
    5. The prohibitions set forth in this subsection II.A shall also include, but not be limited to, a ban on any payment or reimbursement by a lending institution or trade association to a college employee or family member for lodging, meals, or travel to conferences or training seminars unless such payment or reimbursement is related solely to non-college business or is otherwise permitted pursuant to the State Code of Ethics, Connecticut General Statutes §1-84(k). College employees whose duties relate to financial aid may accept food or refreshments provided or paid for by a lender or trade association at a meeting, conference or seminar related to their professional development or training, as permitted under the State Code of Ethics. College employees are not precluded from attending any educational or training program related to financial aid or higher education loans where no registration fee is charged to any attendee because of a lender’s or trade association’s sponsorship or support of the program, and provided that any registration fee is limited to covering the costs associated solely with the education or training component of the program, if permitted pursuant to the State Code of Ethics.
  2. Limitations on Participation on Lender Advisory Boards
    No college trustee, director, officer, agent or employee, or any of their family members shall serve on an advisory board unless such service is unrelated in any way to financial aid or higher education loans. Lenders can obtain advice and opinions of financial aid officials on financial aid products and service through trade associations, industry surveys or other mechanisms that do not require service on lender advisory boards.
  3. Prohibition of Certain Compensation to a College
    1. No college or any of its affiliated organizations may accept any compensation from any lending institution or trade association related to the lending institution’s or trade association’s financial aid or education loan activity. This prohibition shall include, but nor be limited to: (i) revenue sharing by a lending institution or trade association with a college or affiliated organization; (ii) the receipt by a college or affiliated organization from any lending institution or trade association of any equipment or supplies, including, without limitation, computer hardware of software, for which the college or affiliated organization pays below-market prices; and (iii) printing costs or services provided that a college or affiliated organization shall not be prohibited from accepting a lender’s or trade association’s own standard printed brochures or informational material that does not contain the college logo or otherwise identify the college.
    2. Notwithstanding anything else in this subsection II.C, a college may accept assistance comparable to the kinds of assistance provided by the Secretary of the US Department of Education to schools under or in furtherance of the Federal Direct Loan Program.
    3. Nothing in this subsection shall prohibit a college or affiliated organization from accepting endowment gifts, capital contributions, scholarship funding, or other financial support from a lender or trade association, so long as the college gives no competitive advantage or preferential treatment to the lender or trade association related to its education loan activity in exchange for such support.
  4. Preferred Lender Lists
    In the event that a college promulgates a list of preferred or recommended lenders or similar ranking or designation (“preferred lender list”), then:
    1. Every brochure, web page or other document that sets forth a preferred lender list must clearly disclose, textually or by clearly designated hyperlink, the process by which the college selected lenders for said preferred lender list, including but not limited to the criteria used in compiling said list and the relative importance of those criteria; and
    2. Every brochure, web page or other document that sets forth a preferred lender list or identifies any lender as being on said preferred lender list shall state in the same font and same manner as the predominant text on the document that students and their parents have the right and ability to select the education loan provider of their choice, are not required to use any of the lenders on said preferred lender list, and will suffer no penalty from the college for choosing a lender that is not on said preferred lender list;
    3. A college’s selection of preferred lenders and decision as to where or how prominently on the list the lending institution’s name appears shall be based solely on the best interests of the student and parent borrowers, utilizing stated criteria that are limited to benefits provided to borrowers (such as competitive interest rates and repayment terms, quality of loan servicing, and whether loans will be sold) and the ability to work efficiently and effectively with the college to process loans, without regard to the pecuniary interest of the college or to any benefits provided by lending institutions to the college or any of the college’s trustees, officers, directors, agents or employees or their family members or to its affiliated organizations. A college’s selection of any preferred lender shall be limited to the types of loans for which that lender has been selected, based on the benefits to the borrower for those types of loans, and the college’s preferred lender list shall indicate the types of loans for which each lender has been selected as a preferred lender. Nothing in this provision is intended to restrict a college’s ability to exercise its discretion in making its own, final judgment about which lenders best meet the college’s criteria and the needs of its student and parent borrowers.
    4. Colleges shall review their preferred lender lists at least annually;
    5. Colleges shall require that all preferred lenders commit, in writing to disclose to the borrower, at the time a loan is issued: (i) whether the loan may be sold to another lender; (ii) that the loan terms and benefits will not change if the loan is sold to another lender; and (iii) that the loan benefits may change if the borrower chooses to consolidate his or her loans.
    6. Colleges shall ensure that any preferred lender list that they publish to students contains no fewer than three (3) lending institutions.
  5. Prohibition of Lenders’ Staffing of a College Financial Aid Office
    1. No employee or other agent of a lending institution may staff a college financial aid office at any time. Colleges shall ensure that no employee or other representative of a lending institution is ever identified to students or prospective students of the college of their parents as an employee or agent of the college. The foregoing prohibitions notwithstanding, if a college believes that it would benefit students, the college may allow representatives of lenders to conduct informational sessions, such as exit interviews and presentations on loan payment and loan consolidation options, so long as: (i) student attendance is voluntary; (ii) a college representative explains that other lenders may provide similar services; (iii) the affiliation of the lender representative is disclosed at the start of the presentation; (iv) the lender representative does not promote the products or services of any lender; and (v) the college takes reasonable steps to ensure compliance with the requirements of this paragraph.
    2. In the event that a college permits a lender to conduct information sessions or exit interviews as set forth in subsection II.E.1 above, the college must retain control of any such session or interview conducted by the lender. Control of an in-person information session or exit interview conducted by a lender may be evidenced by: (i) a college employee attending such interview or presentation; or (ii) the college recording or videotaping the session or interview. Control of an information session or exit interview conducted electronically, via the Internet, may be evidenced by the college creating or approving in advance the content of such a session or interview.
    3. Proper Execution of Master Promissory Notes
      Colleges shall not link or otherwise direct potential borrowers to any electronic master promissory note or other loan agreement unless the master promissory note or agreement allows borrowers to enter the lender code or name for any lender offering the relevant loan, or unless the college’s link to the electronic master promissory note or agreement informs borrowers of alternative means of entering into a master promissory note or agreement with any lender of the borrower’s choice. Any information that a college provides to borrowers about completing a master promissory note or agreement with a preferred lender must provide the information required in subsections II.D.1 and II.D.2 above.
    4. Requirements for Opportunity Loans
      Colleges may enter into arrangements with lender to provide opportunity loans to students whose credit rating would otherwise preclude them from obtaining loans with reasonable rates and terms. Such arrangements may be made with a preferred lender after a college has selected preferred lenders in accordance with the provisions in subsection II.D above. Colleges shall not request, accept, solicit or consider a lending institution’s offer to provide opportunity loans in exchange for a college’s providing concessions, benefits or promises to the lender.
    5. Revolving Door Prohibition
      1. In the event a college hires an employee who will be employed in the financial aid office of the college or who otherwise will have responsibilities with respect to higher education loans or other financial aid and such employee was employed by a lender during the 12-month period prior to the date of hire by the college, such employee shall be prohibited from having any dealings or interactions with such lender on behalf of the college for a period of twelve (12) months from the date of such employee’s employment with the lender was terminated.
      2. In the event a lender hires an employee who was employed by a college during the 12-month period prior to the date of such employee’s hire by the lender, the college shall be prohibited from having any dealings or interactions with such employee for a period of twelve (12) months from the date such employee’s employment with the college was terminated.
    6. Miscellaneous Provisions
      All provisions of this Code of Conduct should be read in conjunction with the Board of Regents Ethics Statement and with the Code of Ethics for Public Officials, CGS section 1-79 et seq. and with any amendments thereto.

Adopted September 15, 2008 BOT; Revised April 6, 2017 BOR

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