This is the Manhattan School of Music code of conduct for financial aid professionals.
I. 目的
The purpose of this policy is to prohibit conflicts of interest in situations involving student financial aid 和 to establish st和ards of conduct for Manhattan School of Music officers, 员工, 和 agents with responsibility for student financial aid.
II. 适用性
This Policy applies to all 员工 who work in the Office of 金融援助 和 all other College officers, 员工, 和 agents who have responsibilities related to education 贷款s or other forms of student financial aid.
3. 定义
A. 利益冲突: A conflict of interest exists when an employee’s financial interests or other opportunities for personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the employee performs his/her responsibilities at MSM.
B. 礼物: 任何小费, 忙, 折扣, 娱乐, 热情好客, 贷款, or other item having a monetary value of more than a de minimus amount. The term includes a gift of services, 运输, 住宿, 或者吃饭, whether provided in kind, by purchase of a ticket, 预付款, or reimbursement after the expense has been incurred. The term “gift” does not include any of the following:
- a. 标准材料, 活动, or programs on issues related to a 贷款, 默认的厌恶, 默认的预防, 或者金融知识, 比如宣传册, 一个车间, 或培训.
- b. Training or informational material furnished to MSM as an integral part of a training session that is designed to improve the service of a lender, 担保人, or 服务机构 of educational 贷款s to MSM, if such training contributes to the professional development of MSM’s 员工.
- c. 有利的条件, 条件, 和 borrower benefits on an education 贷款 provided to a student employed by MSM or an employee who is the parent of a student if such terms, 条件, or benefits are comparable to those provided to all students of MSM 和 are not provided because of the student’s or parent’s employment with MSM.
- d. Entrance 和 exit counseling services provided to borrowers to meet the College’s responsibilities for entrance 和 exit counseling under federal law, so long as MSM’s 员工 are in control of the counseling, 和 such counseling does not promote the products or services of any specific lender.
- e. Philanthropic contributions to an institution from a lender, 服务机构, or 担保人 of education 贷款s that are unrelated to education 贷款s or any contribution from any lender, 担保人, or 服务机构 that is not made in exchange for any advantage related to education 贷款s.
- f. State education grants, scholarships, or financial aid funds administered by or on behalf of a State.
C. Opportunity pool 贷款: A private education 贷款 made by a lender to a student attending MSM or the family member of such a student that involves a 付款, directly or indirectly, 由MSM的点, 保费, 额外的利益, or financial support to such lender for the purpose of such lender extending credit to the student or the family.
D. Revenue-sharing arrangement: An arrangement between MSM 和 a lender under which (a) a lender provides or issues a 贷款 to students attending MSM or to their families; 和 (b) MSM recommends the lender or the 贷款 products of the lender 和 in exchange, the lender pays a fee or provides other materials benefits, including revenue or profit sharing, to MSM or its 员工.
IV. Institutional Policy Regarding Education Loans 和 Student 金融援助
A. Revenue-Sharing Arrangements
The College will not enter into any revenue-sharing arrangement with any lender.
B. Interaction with Borrowers
When participating in the Federal Direct Loan program, the College will not assign a first-time borrower’s federal 贷款, through award packaging or other methods, to a particular lender. The College will not refuse to certify, or delay certification of, any federal 贷款 based on the borrower’s selection or a particular lender or guaranty agency. When participating in the Federal Direct Loan program, the College may assign a first time borrower’s federal 贷款 to the Federal Government as the lender.
C. 私人贷款
Under no circumstances will the College assign a student’s private student 贷款 to a particular lender, or refuse to certify or delay certification of any private 贷款, based upon the borrower’s selection of lender or guaranty agency. The College will not request or accept from any lender any offer of funds to be used for private education 贷款s, including funds for an opportunity pool 贷款, to students in exchange for the College providing concessions or promises regarding providing the lender with (i) a specified number of federal 贷款s; (ii) a specified federal 贷款 volume; or (iii) a preferred lender arrangement for federal 贷款s.
D. 联合品牌
The College will not permit a private educational lender to use the College’s name, 会徽, 吉祥物, logo, 或者换句话说, 图片, or symbols associated with the College to imply endorsement of private educational 贷款s by that lender.
E. 人员协助
The College will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Nothing in this section, 然而, prevents the College from accepting assistance from a lender related to (i) professional development training for its staff; (ii) providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or (iii) staffing services on a short-term, nonrecurring basis to assist the College with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, federally declared national disasters, 和 other localized disasters 和 emergencies identified by the Secretary of Education.
V. 行为准则
A. 利益冲突
- a. No employee shall have a conflict of interest with respect to any education 贷款 or other student financial aid for which the employee has responsibility.
- b. No employee may process any transaction related to his/her own personal financial aid eligibility or that of a relative.
B. 礼物
- a. No employee may accept any gift from a lender, 担保人, or 服务机构 of education 贷款s. A gift to a family member of an employee or to any other individual based on that individual’s relationship with the employee shall be considered a gift to the employee if the gift is given with the knowledge 和 acquiescence of the employee 和 the employee has reason to believe the gift was given because of the employee’s position at MSM.
- b. Token awards from professional associations (state, 区域, or national) that recognize professional milestones or extraordinary service to parents 和 students, or scholarships for conference attendance or other professional development opportunities, 可以接受.
C. Prohibited Contracting Arrangements
- a. No employee shall accept from any lender or affiliate of any lender any fee, 付款, 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 贷款s.
D. Advisory Board Compensation
- a. No employee who serves on an advisory board, 委员会, or group established by a lender, 担保人, or group of lenders or 担保人s may receive anything of value from the lender, 担保人, or group of lenders or 担保人s in return for that service.
E. Reimbursement of Expenses
- a. Expenses incurred while attending professional association meetings, 会议, or in connection with service on an advisory board, 委员会, or group described in Section V.D. of this Policy must be paid by MSM. Entertainment expenses such as concert or sports tickets or greens fees may not be accepted. Employees are expected to personally pay for such expenses or request reimbursement from MSM in accordance with institution policy.
F. 餐
- a. Employees may occasionally need to share meals with 员工 of lenders, 担保机构, or other colleges or universities in the course of business. 餐 offered as a part of meetings, 会议, or other events 可以接受 if all participants in the meeting or event are offered the meals or if the meals are included as a part of a registration fee.
VI. 违反政策
A. Violations of this Policy may result in disciplinary action, up to 和 including dismissal.
