The Higher Education Opportunity Act (HEOA) of 2008 requires institutions of higher education to develop and enforce a code of conduct that prohibits conflicts of interest. The code of conduct applies to employees and agents of the institution.
UMass Lowell’s code of conduct requires employees to adhere to the following:
  • May not enter into a revenue-sharing arrangements with any lender. Revenue-sharing arrangements include circumstances where an institution recommends a lender or loan products in exchange for a fee or provision of material benefits, including revenue or profit sharing, to the institution, employee, or agent of the institution. 
  • May not accept gifts from a lender, guaranty agency or loan servicer having a monetary value of more than a de minimus amount from a lender, guarantor, or servicer of education loans.  Such gifts include services, transportation, lodging, meals, discount, payment in advance, or reimbursement.
  • Employees with financial aid responsibilities, may not accept any payment or other financial benefit as compensation from a lender or lender affiliate for any type of consulting arrangement or other contract to provide services to a lender.
  • May not direct borrowers to particular lenders.
  • May not refuse or delay loan certifications of any loan based on the lender selected. 
  • May not request or accept from any lender an offer of funds to be used for private education loans in exchange for the university providing the lender with a specified number or volume of federal loans made or in exchange for placement on a preferred lender list.
  • May not request or accept any assistance with call center staffing or financial aid staffing from any lender.
  • Employees with financial aid responsibilities are prohibited from receiving anything of value from a lender or guarantor in return for service on its advisory board. Reimbursement for reasonable expenses incurred in connection with such service, however, is permitted.
The Financial Aid Office at UMass Lowell also adheres to the Code of Conduct developed by NASFAA's Board of Directors. Subject to enforcement procedures that went into effect July 1, 2015, and as an institutional members of NASFAA, UMass Lowell will ensure that: 
1. No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.
a. Employees within the financial aid office will not award aid to themselves or their immediate family members. Staff will reserve this task to an institutionally designated person, to avoid the appearance of a conflict of interest.
b. If a preferred lender list is provided, it will be compiled without prejudice and for the sole benefit of the students attending the institution. The information included about lenders and loan terms will be transparent, complete, and accurate. The complete process through which preferred lenders are selected will be fully and publicly disclosed. Borrowers will not be auto-assigned to any particular lender.
c. A borrower's choice of a lender will not be denied, impeded, or unnecessarily delayed by the institution, even if that lender is not included on the institution's preferred lender list.
d. No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family), or from any entity doing business with or seeking to do business with the institution (including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service).
2. Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.
3. Institutional financial aid offers and/or other institutionally provided materials shall include the following:
a. A breakdown of individual components of the institution's Cost of Attendance, designating all potential billable charges.
b. Clear identification of each aid being offered, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.
c. Standard terminology and definitions, using NASFAA's glossary of terms.
d. Renewal requirements for each aid being offered.
4. All required consumer information is displayed in a prominent location on the institutional web site(s) and in any printed materials, easily identified and found, and labeled as "Consumer Information." 
5. Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.
Refer to NASFAA's Statement of Ethical Principles, Enforcement Procedures, as well as the Ethical Principles, Code of Conduct and Enforcement Procedures Q&A for more information about NASFAA's ethical guidelines and how they are enforced. To report a potential violation of NASFAA's Code of Conduct, refer to the Ethics Complaint Submission Form