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This policy is applicable to Strayer University's officers, employees, and agents, and it prohibits a conflict of interest with their responsibilities with respect to Title IV loans. The policy is part of Strayer University's commitment to the highest ethical standards and conduct by its employees. It supplements the Code of Conduct stated in the Employee Handbook and the Strayer Education, Inc. Code of Business Conduct, and applies specifically to conduct related to financial aid.
Strayer University expects the highest levels of professionalism and ethical behavior from all officers, employees, and agents whose responsibilities include student financial aid matters. These individuals must avoid even the appearance or perception of any conflict of interest regarding their student aid responsibilities. They must refrain from taking any action they believe is contrary to law, regulation, or the best interest of the students they are serving, and must disclose all conflicts identified in this policy.
Strayer University Responsibilities
As part of its commitment to the highest ethical standards in connection with its responsibilities regarding Federal financial aid, Strayer University will not:
- Receive anything of value from any lender in exchange for any advantage sought by the lender in making educational loans available to enrolled or prospective students of Strayer University.
- Assign, through award packaging or other methods, a first-time 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.
- Enter into any revenue-sharing arrangement with any lender under which Strayer University recommends a lender or its products in exchange for a fee or other material benefits from the lender, and the lender provides or issues a loan that is made, insured, or guaranteed under Title IV to students attending Strayer University (or their families).
- 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 concessions or promises to provide the lender with a specified number of loans made, insured, or guaranteed under Title IV; a specified loan volume of such loans; or a preferred lender arrangement for such loans.
- Request or accept from any lender any assistance with call center staffing or financial aid office staffing.
- Use Federal funds received under Federal financial aid programs to hire a registered lobbyist or pay any person or entity for securing an earmark to any legislation. Strayer University will not use such funds to pay any person for influencing or attempting to influence an officer or employee of any Agency, Member of Congress, officer or employee of Congress, or employee of a Member of Congress in connection with the awarding of any Federal contract, making of any Federal grant or loan, entering into any Federal cooperative agreement, or the extension, continuation, renewal, amendment or modification of any Federal contract, grant, loan or cooperative agreement.
Responsibilities of Strayer University Officers, Employees and Agents
Any officer or employee, or agent of Strayer University who is employed in the financial aid office of Strayer University, or who otherwise has responsibilities with respect to educational loans or other financial aid of Strayer University, is prohibited from:
- Soliciting or accepting any gift from a lender, guarantor, or servicer of educational loans for any item or service having more than a de minimis monetary value, other than standard materials (brochures, training aids) related to topics such as default prevention or financial literacy. Upon prior approval of the Vice President-Financial Aid, exceptions may be made with for reasonable expenses for professional development that will improve the efficiency and effectiveness of Strayer University's financial aid programs.
- Accepting from a lender or its affiliate any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender relating to education loans.
- Receiving anything of value from a lender, guarantor or group of lenders or guarantors if the employee serves on an advisory board, commission, or group established by a lender or group of lenders. An employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission or group.
Reporting Violations of This Policy
Strayer University expects officers and employees covered by this policy to report violations of this policy to the Vice President - Financial Aid. Failure to comply with this policy will result in disciplinary action, which may include termination of employment.
Questions regarding this policy should be addressed to the Vice President - Financial Aid.