Introduction

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, Dartmouth College financial aid personnel are guided by two statements of professional ethics. The Dartmouth College 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, Dartmouth College personnel are expected to comply fully with all relevant laws, as well as with the College's own high standards of integrity and quality. In addition to complying with specific laws or regulations that govern business activities, standards of fairness, honesty, and respect for the rights of others will govern Dartmouth's conduct at all times.

As members of the National Association of Student Financial Aid Administrators (NASFAA), Dartmouth College financial aid personnel 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 Dartmouth Code of Ethical Business Conduct and the NASFAA Statement, Dartmouth College has adopted this Code of Conduct for financial aid professionals.

Code of Conduct Principles

1. Neither Dartmouth College nor any employee of Dartmouth College who has responsibilities with respect to financial aid shall enter into any revenue-sharing arrangement with any lender.
2. Neither Dartmouth College nor any employee of Dartmouth College who has responsibilities with respect to financial aid, nor any members of their family, shall accept any gift from a lender, guarantor, or servicer of educational loans. For this purpose, a "gift" means any gratuity, favor, discount, entertainment, hospitality, loan or other item having more than de minimus value. However, an employee who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group.
3. No employee of Dartmouth College who has responsibilities with respect to financial aid shall accept from any lender any fee, payment, or other financial benefit as compensation for any type of consulting arrangement.
4. Dartmouth College shall 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. Dartmouth College shall 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 institution providing concessions or promises to the lender regarding a number of loans, loan volume, or a preferred lending arrangement for such loans.
6. Dartmouth College shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing.
7. In addition, Dartmouth College employees who have responsibilities with respect to financial aid shall:
   1. Refrain from taking any action for their personal benefit.
   2. Refrain from taking any action they believe is contrary to law, regulation, or the best interests of the students and parents they serve.
   3. Ensure that the information they provide is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
   4. Be objective in making decisions and advising their institution regarding relationships with any entity involved in any aspect of student financial aid.
   5. Disclose to the Director of Financial Aid any involvement with or interest in any entity involved in any aspect of student financial aid.