Code of Conduct for Financial Aid Staff

Santa Clara University is committed to administering financial aid with integrity and in the utmost ethical manner to support students and their families. To that end, the University has adopted the following Code of Conduct for all University employees who have responsibilities for or participate in any way in the administration of financial aid (“financial aid staff”):

Consistent with the National Association of Student Financial Aid Administrators (NASFAA)’s Code of Conduct for Institutional Financial Aid Professionals:

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. 1. Financial aid staff 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 publicly 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 their 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:

• • Breakdown of estimated individual Cost of Attendance components, including which are direct (billed by the institution) costs vs. indirect (not billed by the institution) costs
  • Clear identification and proper grouping of each type of aid offered indicating whether the aid is a grant, scholarship, loan, or work program
  • Estimated net price
  • Standard terminology and definitions, using NASFAA's glossary of terms
  • Renewal requirements for each aid type being offered as well as next steps and financial aid office contact information

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 staff 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.
   
   
6. Financial aid staff are expected to comply with NASFAA’s Statement of Ethical Principles.
   
   
7. As a participant in federal student loan programs, financial aid staff will comply with all applicable laws and regulations, including but not limited to those set forth in Section 493(c) of the Higher Education Opportunity Act, addressing conflicts of interest and prohibited revenue-sharing agreements, gifts, and certain contracting arrangements.

Code of Conduct for Financial Aid Staff - Oct 2025