In August, 2008, Congress enacted and the President signed into law the Higher Education Opportunity Act (HEOA), reauthorizing the Higher Education Act of 1965, as amended. Among its many provisions, the HEOA requires every institution participating in federal financial aid programs to adopt a code of conduct and display it prominently on its website.
In addition to the requirements of the HEOA, Vermont Law School financial aid personnel are guided by two statements of professional ethics. The Vermont Law School Code of Ethical Business Conduct emphasizes that the College seeks to adhere to the highest ethical standards in all that it does. Among other things, Vermont Law School personnel are expected to comply with all relevant laws, as well as with the School’s own high standards of integrity and quality. In addition to complying with specific laws or regolations that govern business activities, standards of fairness, honesty, and respect for the rights of others will govern Vermont Law School’s conduct at all times.
As a member of the National Association of Student Financial Aid Administrators (NASFAA), Vermont Law School financial aid personally also adhere to the NASFAA Statement of Ethical Principles and Code of Conduct which contains principles specific to the financial aid profession. Consistent with the requirements of the HEOA and the provisions of the Vermont Law School of Ethical Business Conduct and the NASFAA Statement, Vermont Law School has adopted this Code of Conduct for financial aid professionals.
Code of Conduct Principles
The following Code of Conduct was last updated by NASFAA's Board of Directors in March 2014. Institutional members of NASFAA will ensure that:
- No action will be taken by financial aid staff that is for their personal benefit or coold be perceived to be a conflict of interest.
- Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
- If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be folly and publically disclosed. Borrowers will not be auto-assigned to any particolar lender.
- A borrower's choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution, even if that lender is not included on the institution's preferred lender list
- No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family), or from any entity doing business with or seeking to do business with the institution (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).
- Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.
- Institutional award notifications and/or other institutionally provided materials shall include the following:
- A breakdown of individual components of the institution's Cost of Attendance, designating all potential billable charges.
- Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.
- Standard terminology and definitions, using NASFAA's glossary of award letter terms.
- Renewal requirements for each award.
- All required consumer information is displayed in a prominent location on the institutional web site(s) and in any printed materials, easily identified and found, and labeled as "Consumer Information."
- Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.