WAU 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.