The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest for financial aid personnel. In accordance with this requirement, Saint Mary's College has created the following code of conduct. Any questions regarding interpretation of, or definitions used in, this Code of Conduct should be interpreted based on the HEOA of 2008.

This policy applies to all employees who work in the Financial Aid Office and all other College employees, officers and agents who have responsibilities with respect to education loans.

Code of Conduct

Conflict of Interest

  • No employee shall have a conflict of interest1 with respect to any education loan or other student financial aid for which the employee has responsibility
  • Employees may not process any transaction related to their own personal financial aid eligibility or that of a relative.2

Ban on Revenue Sharing

Saint Mary's College has not, and will not in the future,  enter into any revenue-sharing arrangements with any lender.

Gift Ban

Employees or their family members may not solicit and/or accept any gifts from lenders, guarantors, or servicers of education loans. A gift to a family member of an employee or to another individual based on that individual’s relationship with an employee shall be considered a gift to the employee if the gift is given with the knowledge and consent of the employee, and the employee has reason to believe the gift was given because of the employee’s position at the College. Token awards from professional associations that recognize professional milestones or extraordinary service to parents and students, or scholarships for conference attendance or other professional development opportunities, may be accepted.

The College will not accept any marketing gifts from lenders but may accept and distribute educational materials regarding banking services (excluding student loans).

Prohibition on Contracting

Employees who work in the Financial Aid Office or who have responsibilities related to education loans may not accept from any lender or lender affiliate any fees, payments, or other financial benefit as compensation (including the opportunity to purchase stock) for any type of consulting arrangement or other contract to provide services to a lender relating to education loans.

Interaction with Borrowers

The College will also not refuse to certify, or delay certification of, any alternative student loan based on the borrower’s choice of lender.

Prohibition on Offers of Funds for Private Loans

Saint Mary's College does not request or accept from any lender an offer of funds to be used for private education loans in exchange for promises to the lender with regards to the number of loans made, specific loan volume or preferred lender arrangement.


The College will not permit a private educational lender to use the College’s name, emblem, logo or any other words, pictures or symbols associated with the College to imply endorsement of private education loans by that lender.

Ban on Staffing Assistance

The College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. However, nothing in this section prevents the College from accepting assistance from a lender or guarantor in regards to: professional development training for College staff, providing educational counseling materials, financial literacy materials or debt management materials to borrowers.

Advisory Board Compensation

No employee who serves on an advisory board, commission or group established by a lender, guarantor, or group of lenders or guarantors may receive anything of value form the lender, guarantor, or group of lenders or guarantors in return for that service.

Reimbursement of Expenses

Expenses incurred while attending professional association meetings, conferences, or in connection with service on an advisory board or commission must be paid by the College. Payment for entertainment expenses may also not be accepted from any lender, guarantor or servicer.

Meals offered as part of meetings, conferences professional development activities or other events may be accepted if all participants in the meeting or event are offered the meals, or if the meals are included as part of the registration fee.

1A conflict of interest exists when an employee’s financial interest or other opportunities for personal benefit may compromise, or reasonable appear to compromise, the independent judgment with which the employee performs his or her responsibilities at the College.

2For the purpose of this policy, a “relative” is defined as an individual with whom an employee has a relationship by blood, marriage, adoption, domestic partnership, or other personal relationship in which objectivity might be impaired.