Code of Conduct

NMU Code of Conduct for Institution Financial Aid Professionals

The Higher Education Opportunity Act conditions the eligibility of educational institutions to participate in Title IV programs on the development of and compliance with a code of conduct prohibiting conflicts of interest for its financial aid personnel [HEO § 487(a)(25)].  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 staff of Northern Michigan University is committed to the highest standards of professional conduct.

We invite you to contact us if you have any questions.

In keeping with these high standards, a financial aid professional will:

  • We refrain from taking any action for his or her personal benefit;
  • We refrain from taking any action we believe is contrary to law, regulation, or the best interests of the students and parents we serve;
  • We ensure that the information we provide is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain;
  • We are objective in making decisions and advising NMU regarding relationships with any entity involved in any aspect of student financial aid;
  • We will disclose to NMU, based on NMU's "Conflict of Interest" policy, any possible conflicts of interest including involvement with any entity involved with student financial aid;
  • We 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 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;
  • We do not solicit or accept any gifts or compensation nor participate in revenue-sharing arrangements with any lender, guaranty agency, or servicer.  Gifts include, but are not limited to; gratuity, favors, discounts, entertainment, hospitality, loans, or other items worth more than a negligible amount.  However, a gift does not include:
    1. a brochure, workshop, or training using standard materials relating to a loan, default aversion, or financial literacy, such as a brochure, workshop or training:
    2.  food, training, or informational material provided as part of a training session designed to improve the service of a lender, guarantor, or servicer if the training  contributes to the professional development of the institution's officer, employee, or agent;
    3. favorable terms and benefits on an education loan provided to a student employed by the institution if those terms and benefits are comparable to those provided to all students at the institution;
    4. entrance and exit counseling materials or presentations as long as the institution's staff are in control of the counseling and the counseling does not promote the services of a specific lender;
    5.  philanthropic contributions from a lender, guarantor, or servicer that are unrelated to education loans or any contribution that is not made in exchange for advantage related to education loans, and;
    6. State education grants, scholarships, or financial aid funds administered by or on behalf of a State:
  • No NMU Financial Aid Office employee or officer (or employee or agent who otherwise has responsibilities with respect to education loans) may accept from a lender or an affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans;
  • We will not steer borrowers to particular lenders or delay loan certification;
  • We will not request or accept offers of funds for private loans.  An institution may not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender, or a preferred lender arrangement.  An "opportunity pool loan" is defined as a private education loan made by a lender to a student (or the student's family) that involves a payment by the institution to the lender for extending credit to the student;
  • We will not request or accept staffing assistance from any lender for call center staffing or financial aid office staffing, except on a short-term, nonrecurring basis during emergencies or disasters;
  • We will not accept advisory board compensation.  An employee of NMU's Financial Aid Office (or employee who otherwise has responsibilities with respect to education loans or financial aid) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) is prohibited from receiving anything of value from the lender, guarantor, or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board.

The NMU Financial Aid Office Staff are members of the National Association of Student Financial Aid Administrators (NASFAA) and follow their Code of Conduct and Statement of Ethical Principles.

Statement of Ethical Principles

The primary goal of the financial aid professional is to help students achieve their educational goals through financial support and resources. NASFAA members are required to exemplify the highest level of ethical behavior and demonstrate the highest level of professionalism. The following guidelines were last updated by NASFAA's Board of Directors in March 2014.

We, financial aid professionals, declare our commitment to the following Statement of Ethical Principles.

Financial aid administrators shall:

Advocate for students 

  • Remain aware of issues affecting students and continually advocate for their interests at the institutional, state and federal levels.
  • 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. 

Manifest the highest level of integrity 

  • Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.
  • 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.
  • Protect the privacy of individual student financial records.
  • Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.

Support student access and success 

  • Commit to removing financial barriers for those who want to pursue postsecondary learning and support each student admitted to our institution.
  • Without charge, assist students in applying for financial aid funds.
  • Provide services and apply principles that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.
  • Understand the need for financial education and commit to educate students and families on how to responsibly manage expenses and debt.

Comply with federal and state laws 

  • Adhere to all applicable laws and regulations governing federal, state, and institutional financial aid programs.
  • 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.
  • 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.

Strive for transparency and clarity  

  • Provide our students and parents with the information they need to make good decisions about attending and paying for college.
  • 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.
  • Ensure equity by applying all need-analysis formulas consistently across the institution's full population of student financial aid applicants.
  • Inform institutions, students, and parents of any changes in financial aid programs that could affect their student aid eligibility.

Protect the privacy of financial aid applicants 

  • Ensure that student and parent private information provided to the financial aid office 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).
  • 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.

Revised March 2014     

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