Student Consumer Information
The Higher Education Act of 1965 (HEA), as amended by the Higher Education Opportunity Act of 2008 (HEOA), includes many disclosures and reporting requirements that a postsecondary education school is required to distribute or make available to prospective and current students, and other consumers.
CODE OF CONDUCT
Hilbert College hereby adopts the following provisions from the HEOA, Section 493 as its Code of Conduct Related to Student Loan Activities and will annually inform all institutional officers, employees, and agents with responsibilities for the student loan activities and decisions of the provisions of this code.
(1) BAN ON REVENUE-SHARING ARRANGEMENTS
(A) Prohibition – The institution shall not enter into any revenue-sharing arrangement with any lender.
(B) Definition – For purposes of this paragraph, the term ‘revenue-sharing arrangement’ means an arrangement between an institution and a lender under which
(i) a lender provides or issues a loan that is made, insured, or guaranteed under this title to students attending the institution or to the families of such students; and (ii) the institution recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other material benefits, including revenue or profit sharing, to the institution, an officer or employee of the institution, or an agent.
(2) GIFT BAN
(A) Prohibition – No officer or employee of the institution who is employed in the Office of Financial Aid, or an individual who has been assigned by the Hilbert College President with supervisory authority over the Director of Financial Aid, or who otherwise has responsibilities with respect to educational loans, or agent who has responsibilities with respect to educational loans, shall solicit or accept any gift from a lender, guarantor, or servicer of education loans.
(B) Definition of gift
(i) In General – In this paragraph, the term ‘gift’ means any gratuity, favor, discount, entertainment, hospitality, stock, or other item having a monetary value of more than a de minimus amount ($25 per year). The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, computer hardware, printing costs or services for which the recipient pays below-market value, payment in advance, or reimbursement after the expense has been incurred.
(ii) Exceptions – The term ‘gift’ shall not include any of the following:
(I) Standard material, activities, or programs on issues related to a loan, default aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
(II) Food, refreshments, training, or informational material furnished to an officer or employee of an institution, or to an agent, as an integral part of a training session that is designed to improve the service of a lender, guarantor, or servicer of education loans to the institution, if such training contributes to the professional development of the officer, employee, or agent. Reimbursement of expenses to a covered institutional employee for serving on the board of a bona-fide professional association recognized by the Commissioner of NYS Education Dept., related to student financial aid.
(III) Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the institution if such terms, conditions, or benefits are comparable to those provided to all students of the institution.
(IV) Entrance and exit counseling services provided to borrowers to meet the institutions responsibilities for entrance and exit counseling as required by subsections (b) and (l) of section 485, as long as –
(aa) the institution’s staff are in control of the counseling, (whether in person or via electronic capabilities); and (bb) such counseling does not promote the products or services of any specific lender.
(V) Philanthropic contributions to an institution from a lender, servicer, or guarantor of education loans that are unrelated to education loans or any contribution from any lender, guarantor, or servicer that is not made in exchange for any advantage related to education loans.
(VI) State education grants, scholarships, or financial aid funds administered by or on behalf of the state.
(3) HILBERT IS COMMITTED TO THE NASFAA CODE OF CONDUCT
(A) Refrain from taking any action for his or her personal benefit
(B) Refrain from taking any action he or she believes is contrary to law, regulation, or the best interests of the students and parents he or she serves
(C) Ensure that the information he or she provides is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
(D) Be objective in making decisions and advising his or her institution regarding relationships with any entity involved in any aspect of student financial aid.
(E) Refrain from soliciting or accepting anything of other than nominal value from an entity (other than an institution of higher education or a government entity such as the U.S. Department of Education) involved in the making, holding, consolidating or processing or any student loans, including anything of value (including reimbursement of expenses) for serving on an advisory body or as part of a training activity or sponsored by any such entity.
(F) Disclose to his or her institution, in such manner as his or her institution may prescribe, any involvement with or interest in any entity involved in any aspect of student financial aid.
CONFIDENTIALITY OF STUDENT RECORDS
With regard to privacy, personally identifiable information may not be disclosed to others without prior written consent of the student, except for specific cases defined by the U.S. Department of Education. The school must annually distribute to all enrolled students a notice of the availability of the information that is required to be made available to students under the Family Educational Rights and Privacy Act (FERPA). This act is also known as the Buckley Amendment which was passed by Congress in 1974.
FERPA will provide guidance with regard to privacy about a student's record and personally identifiable information. A notice must list and briefly describe the information and include a statement of the procedures required to obtain the information. Information will need to include the following: the right of the student to inspect and review their education records; requests for amendments of their education records; guidelines for the correction of inaccurate and misleading data; and procedures to file a complaint with the U.S. Department of Education concerning alleged failures by the school.
FERPA information is published in the Hilbert College Student Handbook and is also available online here: FERPA
For additional questions or concerns, contact the Registrar’s Office (716-649-7900)