Code of Conduct for Financial Aid Professionals

Policies and Procedures

Code of Conduct for Financial Aid Professionals

Barry University financial aid professionals are expected to maintain the highest standards of professional conduct in all aspects of their responsibilities. In doing so, the Financial Aid Office is committed to administering student financial aid with integrity, transparency, and in compliance with all applicable federal and state regulations, including the Higher Education Opportunity Act (HEOA), as well as the ethical principles established by the National Association of Student Financial Aid Administrators (NASFAA).

Financial aid professionals are expected to uphold both the letter and spirit of these standards in all interactions with students, parents, colleagues, lenders, servicers, and external partners.

Financial aid professionals will:

  • Refrain from taking any action for personal benefit or that creates an actual or perceived conflict of interest.
  • Refrain from any action that is contrary to applicable laws, regulations, or the best interests of students and their families.
  • Provide information that is accurate, complete, and unbiased, and does not reflect any preference arising from actual or potential personal gain.
  • Exercise objectivity in making decisions and advising the University regarding relationships with any entity involved in student financial aid. 
  • Disclose to the University any outside employment, financial interest, or other relationship that could create an actual or perceived conflict of interest.
  • Not award financial aid to themselves or to members of their immediate family. Such determinations will be made by an institutionally designated official to avoid the appearance of a conflict of interest. 

Barry University will maintain strict compliance with federal requirements and prohibits the following:

  • The University shall not enter into any revenue-sharing arrangement with any lender.
  • No University officer or employee within the Financial Aid Office, or any employee with responsibilities related to education loans, shall solicit or accept any gift (including gratuities, favors, discounts, entertainment, hospitality, loans, or any item of monetary value exceeding a de minimis amount) from a lender, guarantor, or servicer of education loans.
  • No University officer or employee within the Financial Aid Office, or any employee with responsibilities related to education loans, shall accept any fee, payment, or other financial benefit (including stock or investment opportunities) from any lender or affiliate as compensation for consulting or other services.
  • The University shall not request or accept any offer of funds for private education loans in exchange for:
    • A specified loan volume or number of loans;
    • Loan guarantees or insurance commitments; or
    • A preferred lender arrangement. 
  • The University shall not request or accept assistance from any lender with call center or financial aid office staffing.
  • Employees within the Financial Aid Office, or those with responsibilities related to education loans, shall not serve on advisory boards, commissions, or similar groups established by lenders, guarantors, or groups of lenders or guarantors. 

If the University maintains or references a preferred lender list, it will adhere to the following principles:

  • The list will be developed solely for the benefit of students using transparent, objective, and documented criteria.
  • The process for selecting preferred lenders will be fully disclosed and made available upon request. 
    Students will not be auto-assigned to any lender under any circumstances.
  • A student’s choice of lender will not be denied, impeded, or unnecessarily delayed, including lenders not included on any institutional list. 

Financial aid offers and related materials will:

  • Clearly distinguish between grants/scholarships, loans, and work-study employment.
  • Include a breakdown of Cost of Attendance, identifying:
    • Direct costs (billed by the University)
    • Indirect costs (not billed by the University)
  • Provide an estimated net price where applicable.
  • Use consistent terminology aligned with NASFAA’s glossary and federal guidance.
  • Include renewal requirements for each type of aid offered.
  • Provide clear next steps and Financial Aid Office contact information. 

All required consumer information will be prominently displayed on the University’s website(s) and included in applicable printed materials. Information will be clearly labeled as “Consumer Information” and organized to ensure it is easily accessible and understandable to students and families.

Barry University financial aid professionals are expected to comply with all applicable federal and state laws, regulations, and institutional policies governing student financial aid.

Employees are expected to seek guidance when ethical or regulatory uncertainty arises and to act at all times in the best interest of students and families.

Failure to comply with this Code of Conduct may result in disciplinary action, up to and including termination of employment, in accordance with University policy.

As a member institution of the National Association of Student Financial Aid Administrators (NASFAA), Barry University also adheres to NASFAA’s Statement of Ethical Principles and professional standards for institutional financial aid professionals. These principles guide ethical decision-making and reinforce the University’s commitment to integrity, transparency, and student-centered financial aid administration.

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