Ethical Principles Adhered to by Student Financial Services

National Association of Student Financial Aid Administrators (NASFAA)

The primary goal of the financial aid professional is to help students achieve their educational goals through financial support and resources. To this end, this statement provides the financial aid professional with a set of principles that serves as a common foundation for accepted standards of conduct. The staff of the Office of Financial Aid and the Student Accounts Office at Empire State University follows these principles and the code of conduct outlined by NASFAA.

Statement of Ethical Principles

The financial aid professional shall:

  1. Remain aware of issues affecting students and continually advocate for their interests at the institutional, state and federal levels.
  2. Support federal, state and institutional efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school.
  3. Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.
  4. Deal with others honestly and fairly, abiding by our commitments and always acting in a manner that merits the trust and confidence others have placed in us.
  5. Protect the privacy of individual student financial records.
  6. Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.
  7. Commit to removing financial barriers for those who want to pursue postsecondary learning and support each student admitted to our institution.
  8. Without charge, assist students in applying for financial aid funds.
  9. Provide services and apply principles that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.
  10. Understand the need for financial education and commit to educate students and families on how to responsibly manage expenses and debt.
  11. Adhere to all applicable laws and regulations governing federal, state, and institutional financial aid programs.
  12. Actively participate in ongoing professional development and continuing education programs to ensure ample understanding of statutes, regulations, and best practices governing the financial aid programs.
  13. Encourage colleagues to participate in the financial aid professional associations available to them at the state, regional, or national level and offer assistance to other aid professionals as needed
  14. Provide our students and parents with the information they need to make good decisions about attending and paying for college.
  15. Educate students and families through quality information that is consumer-tested when possible. This includes (but is not limited to) transparency and full disclosure on award notices.
  16. Ensure equity by applying all need-analysis formulas consistently across the institution's full population of student financial aid applicants.
  17. Inform institutions, students, and parents of any changes in financial aid programs that could affect their student aid eligibility.
  18. Strive to ensure that cost of attendance components are developed using resources that represent realistic expenses.
  19. Ensure that student and parent private information provided to the Office of Financial Aid by financial aid applicants is protected in accordance with all state and federal statutes and regulations, including FERPA and the Higher Education Act, Section 483(a)(3)(E) (20 U.S.C. 1090).
  20. Protect the information on the FAFSA from inappropriate use by ensuring that this information is only used for the application, award, and administration of aid awarded under Title IV of the Higher Education Act, state aid, or aid awarded by eligible institutions.

The guidelines above were last updated by NASFAA's Board of Directors in November 2017.

Code of Conduct for Institutional Financial Aid Professionals

An institutional financial aid professional is expected to always maintain exemplary standards of professional conduct in all aspects of carrying out his or her responsibilities, specifically including all dealings with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized or regulated activity.

The financial aid professional shall:

  1. refrain from taking any action for his or her personal benefit.
  2. refrain from taking any action he or she believes is contrary to law, regulation, or the best interests of the students and parents he or she serves.
  3. ensure that the information he or she provides is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
  4. be objective in making decisions and advising his or her institution regarding relationships with any entity involved in any aspect of student financial aid.
  5. refrain from soliciting or accepting anything of other than nominal value from any entity (other than an institution of higher education or a governmental entity such as the U.S. Department of Education) involved in the making, holding, consolidating or processing of any student loans, including anything of value (including reimbursement of expenses) for serving on an advisory body or as part of a training activity of, or sponsored by, any such entity.
  6. disclose to his or her institution, in such manner as his or her institution may prescribe, any involvement with, or interest in, any entity involved in any aspect of student financial aid.

Adopted by Board of Directors, May 2007

SUNY Code Of Conduct

Student Loan Practices Code of Conduct: Please note that this pertains to FFELP loans awarded prior to the 2009-2010 school year and to alternative loans. As of the 2009-2010 school year, all Stafford loans are processed through the Direct Loan Program.

Empire State University works diligently to ensure that its officers, employees and agents avoid conflicts of interest in connection with their responsibilities relating to providing and administering student loans for our students. In accordance with state and federal law, you should be aware that the following activities are prohibited. Some of these prohibitions involve technical definitions which can be found by referring to the applicable state and federal law. If you wish to obtain this information, please contact the Office of Financial Aid.

  1. Empire State University does not enter into any revenue-sharing arrangement with any lender.
  2. No officer, employee or agent of Empire State University who is employed in the Office of Financial Aid or who otherwise has responsibilities with respect to education loans, will solicit or accept any gift or other thing of value from a lender, guarantor, or loans or servicer of education loans. You should be aware that certain items provided or contributed by lenders are not considered gifts, such as training materials, philanthropic contributions unrelated to education loans, and entrance and exit counseling services.
  3. No officer, employee or agent of Empire State university who is employed in the Office of Financial Aid or who otherwise has responsibilities with respect to education loans will accept from any lender or affiliate of any lender, any fee, payment, or other financial benefit (including the opportunity to purchase stock) as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.
  4. Empire State University will not, for any first-time borrower, assign, through award packaging or other methods, the borrower’s loan to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.
  5. Empire State University 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 campus providing concessions or promises regarding providing the lender with a specified number of loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement for such loans.
  6. Empire State University does not request or accept from any lender any assistance with call center staffing or Office of Financial Aid staffing.
  7. No employee of Empire State University who is employed in the Office of Financial Aid or who otherwise has responsibilities with respect to education loans or other student financial aid and who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, will receive anything of value from the lender, guarantor, or group of lenders or guarantors for such service.

Draft Version adopted November 2008