Student Financial Services Code of Conduct

Washington Adventist University’s Student Financial Services Office (WAU SFSO) is a member of the National Association of Student Financial Aid Administrators (NASFAA), the Eastern Association of Student Financial Aid Administrators (EASFAA), and the Delaware District of Columbia-Maryland Association of Student Financial Aid Administrators (DEDCMD ASFAA).

All of our actions and decisions are bound by NASFAA’s Statement of Ethical Principles and Code of Conduct for Institutional Financial Aid Professionals (see below) and regulations developed by the Department of Education of the U.S. Federal Government. Staff in our office will always act in the best interest of our students and their families.

Currently, WAU participates in the Federal Direct Student Loan Program. As such, the Department of Education is the lender for all of our Title IV Federal Student Loans. However, should the Federal Family Education Loan Program (FFELP) be revived, we will adhere to the following code of conduct.

The Higher Education Opportunity Act of 2008 requires educational institutions participating in a Title IV Loan Program to adhere to a Code of Conduct, which prohibits conflicts of interest between Washington Adventist University’s (WAU) officers, employees, and agents with any lender, lender servicer, and/or guarantor. Sections 487 (a) (25) and 487 (e) of the Higher Education Act of 1965, as amended, require the development, administration, and enforcement of a Student Financial Aid Code of Conduct to govern federal student aid programs. Staff members of WAU Student Financial Services Office (SFSO) are bound to act in compliance with the WAU Student Financial Aid Code of Conduct, the Maryland State Code of Conduct, and the Statement of Ethical Principles and Code of Conduct from the National Association of Student Financial Aid Administrators (NASFAA).

Officers, employees, contract employees, trustees, and agents, including alumni associations, booster clubs, foundations, athletic organizations, social, academic, and professional organizations, and other organizations directly or indirectly associated with or authorized by WAU, agree to the provisions of the WAU Student Financial Aid Code of Conduct and will refrain from:

  • Revenue Sharing
    • No officer, employee, or agent of WAU shall enter into any revenue-sharing or profit-sharing arrangement with any lender.
  • Denial of Borrower’s Lender Choice
    • The WAU SFSO shall not deny or delay a Federal Family Education Loan Program (FFELP) borrower his/her choice of a FFELP Lender or Guarantor. The WAU SFSO shall not assign, through any awarding, certifying, or packaging method, a borrower’s loan to a particular lender.
  • Prepackaging Private/Alternative Loans
    • The WAU SFSO will not package a private/alternative education loan as part of the student’s financial aid award, unless the student has signed the FFELP Waiver Form and continues to agree to the terms and conditions of the private/alternative loan. The WAU SFSO may suggest that a student borrow under the private/alternative program if the borrower is ineligible for additional funding, has exhausted the limits of the Title IV loan programs, or refuses to complete the Free Application for Federal Student Aid.
  • Accepting Gifts, Goods, and/or Services
    • No officer, employee, or agent shall solicit or accept impermissible gifts, goods, and/or services from a FFELP or private/alternative lender, lender servicer, and/or guarantor. A gift to any family member of the above mentioned is also not permissible. Gifts, goods, and/or services include: gratuities, meals, travel, lodging, entertainment (expenses for shows, sporting events, or alcoholic beverages), favors, loans, discounts, hospitality (such as private parties of select training or conference attendees), and in-kind services, such as printing customized consumer information for borrowers with the WAU school logo. WAU SFSO staff may accept only items of nominal value, certain services, and/or certain materials. Permissible gifts would include items such as pens, pencils, notepads, sticky-notes, rulers, calculators, small tote bags, and other individual office supply items. An employee may accept any general items of value from a lender, lender servicer, and/or guarantor provided that the item is also offered to the general public. WAU SFSO staff may accept informational brochures and can participate in meals, refreshments, and receptions in conjunction with meetings and trainings that contribute to his/her professional development, and conference events open to all attendees.
  • Accepting Philanthropic Contributions
    • No officer, employee, or agent shall accept philanthropic contributions from a lender, lender servicer, and/or guarantor that are related to the educational loans provided by the lender, lender servicer, and/or guarantor or that is made in exchange for any advantage related to the educational loan. Educational loans here include loans made by WAU under the private/alternative loan program. WAU will not accept scholarships or grants from a lender or guarantor in exchange for FFELP applications, referrals, a promised loan volume, or placement on the WAU recommended lender list.
  • Advisory Board Compensation
    • WAU employees with responsibility for any financial aid services will not accept anything of value for serving on or otherwise participating as a member of an advisory council or advisory board for a lender, lender affiliate, lender servicer, or guarantor, except that the employee may be reimbursed for reasonable expenses incurred while serving in such capacities.
  • Accepting Compensation for Consulting
    • No officer, employee, or agent shall accept from a lender or its affiliate any fee, payment, or other financial benefit, including the opportunity to purchase stock, as compensation for any type of consulting arrangement or other contract to provide education loan-related services to or on behalf of the lender.
  • Lender Staff Assistance
    • WAU will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. WAU may accept from a lender professional development training and training materials, educational counseling materials, or staffing services on a short-term, nonrecurring basis during emergencies or disasters.
  • Competitive Rates Based on Loan Volume
    • The WAU SFSO shall not request or accept competitive rates on private/alternative loans in exchange for a specified amount of loan activity or in exchange for endorsing the lender’s FFELP loans.
  • Lender Affiliated Employment
    • WAU SFSO staff members shall not accept full time or part time employment with any educational loan lender, lender servicer, and/or guarantor. Staff members who are approached by these entities shall immediately disclose this information to the SFSO Director.

WAU will not use a Preferred Lender List; however, the SFSO will make use of a Recommended Lender List. WAU SFSO staff shall always be in control of the counseling sessions and will not permit the lender and/or guarantor representative to promote in any way the specific lender’s products or services. WAU will make use of the various lender and/or guarantor’s materials and products to aid students in financial literacy.

WAU is committed to providing the information and resources necessary to help every student achieve educational success and will consider the individual needs of each student.

The information contained herein has been provided to all WAU officers, employees, and agents affiliated with this college. In addition, this Student Financial Aid Code of Conduct will be published on the WAU website and at least annually will update the code and inform the officers, employees, and agents of the provisions of this code. Staff, employees, and agents affiliated with this college who fail to comply with this policy will be subject to all applicable disciplinary actions.

The State of Maryland’s Code of Conduct

The primary goal of the financial aid professional is to help students achieve their educational potential by providing appropriate financial resources. To this end, the WAU Student Financial Aid Office will abide by the College Loan Code of Conduct adopted by the State of Maryland under the direction of Attorney General, Brian Frosh, on June 13, 2007. In addition, we will adhere to the Statement of Ethical Principles and the Code of Conduct from the National Association of Student Financial Aid Administrators, adopted in April 1999 and amended in May 2007:

College Loan Code of Conduct adopted by the State of Maryland under the direction of Attorney General, Brian Frosh on June 13, 2007:

  1. Revenue Sharing Restrictions: Colleges may not receive anything of value from any lending institution in exchange for any advantage sought by the lending institution. Lenders cannot pay to get on a school’s preferred lender list.
  2. Gift and Trip Restrictions: College employees may not take anything, including trips, of more than nominal value from any lending institution, when such things are offered in connection with the employees’ financial aid work.
  3. Advisory Board Compensation Rules: College employees with responsibilities for financial aid work may not receive anything of value for serving on the advisory board of any lending institution.
  4. Preferred Lender Guidelines: College preferred lender lists must be based solely on the best interests of the students who may use the list without regard to financial interests of the college.
  5. Preferred Lender Disclosure: On all preferred lender lists the college must clearly and fully disclose the criteria and process used to select preferred lenders. Students must also be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.
  6. Loan Resale Disclosure: Colleges may not permit a lender to appear on a preferred lender list unless the lender agrees to disclose to the student at the time of the loan any pre-existing agreements to sell the loan to another lender.
  7. Call Center Restrictions: Colleges may not permit employees or agents of lenders to identify themselves to students as employees of the colleges. No employee or agent of a lender may be employed by a college financial aid office.

Statement of Ethical Principles

Statement of Ethical Principles from the National Association of Student Financial Aid Administrators, adopted in April 1999, amended in May 2007, March 2014, and November 2017.

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 November 2017.

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.
  • Strive to ensure that cost of attendance components are developed using resources that represent realistic expenses.

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.

Code of Conduct

The following Code of Conduct was last updated by NASFAA’s Board of Directors in March 2014. Subject to enforcement procedures that go into effect July 1, 2015, NASFAA institutional members of NASFAA 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.
  1. 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.
  2. 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 publically disclosed. Borrowers will not be auto-assigned to any particular lender.
  3. 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.
  4. 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).
  1. Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.
  2. Institutional award notifications and/or other institutionally provided materials shall include the following:
  1. A breakdown of individual components of the institution’s Cost of Attendance, designating all potential billable charges.
  2. Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.
  3. Standard terminology and definitions, using NASFAA’s glossary of award letter terms.
  4. Renewal requirements for each award.
  5. 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.”
  6. 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.


The National Association of Student Financial Aid Administrators (NASFAA) supports the training, diversity, and professional development of financial aid administrators; advocates for public policies and programs that increase student access to and success in postsecondary education; and serves as a forum for communication and collaboration on student financial aid issues.



Cost of Attendance (COA): The estimated cost of attending this institution for one academic year. This amount includes the following:

  • Expected charges for one year of tuition and fees
    • Tuition – Charges assessed for classes
    • Fees – Charges assessed for other college services
  • Room and board for resident students
  • Estimated living expense — allowance for rent, utilities, and food for off-campus living
  • Estimated transportation costs
  • Estimated books and supplies
  • Miscellaneous costs

Direct Costs: Expenses the student/family pays to the college.

Educational Loan: A form of financial aid that must be repaid with interest. Educational loans have varying interest rates and repayment terms. Students and/or parents are required to sign a promissory note when accepting an educational loan.

  • Student Loan: Funds awarded to the student that must eventually be paid back to the lender by the student.
    • Federal Direct Student Loan: Loan funds provided to the student by the U.S. Department of Education, through the school. Repayment of principal begins six months after the borrower ceases to be a student on at least a half-time basis. The Free Application for Federal Student Aid (FAFSA) is the annual application. There are two types of Federal Direct Student Loans: subsidized and unsubsidized. Students with financial need can qualify for a subsidized loan, and the government pays the interest on the loan while the student remains enrolled at least half time. Students who don’t demonstrate financial need qualify for an unsubsidized loan and interest accrues while the student is in school.
    • Federal Perkins Loan: A low interest loan for educational expenses provided by the federal government for qualified individuals with exceptional financial need as defined by the institution. .The Federal Perkins Loan needs to be repaid with interest once the student is no longer enrolled at least half-time.
    • Federal Grad PLUS Loan: Loan funds provided to graduate students by the U.S. Department of Education, through the school. This federal loan program allows graduate students with no adverse credit history to apply for up to their Cost of Attendance each year, less any financial aid. To be eligible, the student must be enrolled at least half time in an eligible program of study and first borrow the maximum allowable through the Federal Direct Student Loan program. Repayment of principal and interest begins 30 to 60 days after the loan is fully disbursed with deferment and forbearance options available.
    • Private (Alternative) Loan: A loan from a commercial, state-affiliated or institutional lender used to pay for up to the annual cost of education, less any financial aid received. Private loans usually require the applicant to be creditworthy or have a co-signer and have varying interest rates, fees and repayment options. Repayment of interest (and often principal) generally begins immediately, with some lenders offering deferment options for in-school periods.
  • Federal Parent Loan (PLUS): A federal loan program that allows parents who have no adverse credit history to apply for up to the Cost of Attendance each year, less any financial aid. PLUS loans must be repaid with interest.

Enrollment Level: Level of the degree-granting program in which a student is enrolled. Basic levels of enrollment include: undergraduate (students seeking an associate’s degree, a certificate, or a baccalaureate degree); post-baccalaureate (such as teacher certification); graduate (students working on a master’s degree or professional degree); and post-graduate (such as students enrolled in a doctoral program). The amounts and types of financial aid a student is eligible for is determined, in part, by their enrollment level.

Enrollment Status: Academic workload (or course load), as defined by the institution, that a student is carrying for a defined academic period. This normally relates to the number of credit hours or clock hours taken by a student during a given academic period. For most traditional undergraduate term-based schools:

  • Full-time status = at least 12 credit hours
  • Three-quarter time status = at least 9-11 credit hours
  • Half-time status = at least 6-8 credit hours.

For most clock hour schools full-time enrollment equates to at least 24 clock hours per week.

Expected Family Contribution (EFC): A measure of how much the student and his or her family can be expected to contribute to the cost of the student’s education for the year. The EFC is calculated according to a formula specified in the law and is based upon the information provided by the student and his or her family during the FASFA filing process.

Family Financial Responsibility: Many schools award institutional scholarships and grants based upon a more comprehensive calculation of family financial circumstances using information provided on the CSS PROFILE or the College’s own financial aid form. This can result in a higher (or lower) financial responsibility for the student (and his/her family) than the FAFSA might indicate with its Expected Family Contribution (EFC) estimate.

Federal Pell Grant:  A grant provided by the federal government to qualified undergraduate students who demonstrate exceptional financial need and have an Expected Family Contribution below a threshold designated annually by the U.S. Department of Education, based on the amount of program funds appropriated by Congress.

Federal Supplemental Educational Opportunity Grant (FSEOG): A grant provided by the federal government to qualified undergraduate students who demonstrate exceptional financial need. Priority is given to Pell Grant recipients and funds must be awarded by the school in lowest EFC order.

Federal Work-Study (FWS): A program that provides part-time employment to students attending institutions of higher education who need the earnings to help meet their costs of postsecondary education and encourages students receiving FWS assistance to participate in community service activities.

Gift Aid: Funds awarded to the student that do not have to be repaid, unless the student fails to meet certain terms, such as a service requirement, specified as a condition of the grant. Gift aid includes awards with titles such as grants, scholarships, remissions, waivers, etc. Gift aid can be awarded based upon many factors, including (but not limited to) financial need, academic excellence, athletic, musical, and theatrical talent, affiliation with various groups, or career aspirations.

Grant: Gift aid awarded to the student that does not need to be repaid. Grants are typically based on financial need.

Indirect Costs: Expenses incurred as a result of attendance that the student/family may pay to a third party (merchant, landlord, etc.) other than the college.

Net Cost: Amount of direct and indirect costs remaining after all gift aid (scholarship and grant) is subtracted.

Out-of-pocket Cost: Difference between the cost of attendance and all gift aid. Out-of-pocket cost can be covered through a variety of sources, including: savings, income and educational loans.

Scholarship: Gift aid awarded to the student that does not need to be repaid. Scholarship awards are typically based on merit or a combination of merit and need, such as academic excellence, talent, affiliation with various groups, or career aspirations.

Self-help: Financial aid in the form of loans or student employment. Loans are used to help pay the remaining net costs after gift aid is deducted. Student employment earnings (including Work-Study awards) are generally not deducted from billed costs but can be used to help cover indirect costs and are paid in the form of wages to the student.

Verification: Process to confirm the accuracy of data provided by the applicant on the FAFSA. In order to complete the verification process, students are required to provide certain documents to the school for review.


For more information about financial aid at WAU, email, or call 301.891.4005 or 1-800-835-4212 to speak to a Financial Aid Counselor.

Student Financial Services
Washington Adventist University
7600 Flower Avenue
Takoma Park, MD 20912

Phone: 301-891-4005

Toll-Free: 800-835-4212
General Fax: 301-891-4167