Code of Conduct

Code of Conduct for Financial Aid Professionals

Gogebic Community College (GCC), as a participant in the federal student loan programs, is required to have a code of conduct relating to student financial aid issues that is applicable to the College's agents and employees. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. In addition, the law includes requirements related to the publication of the code and annual disclosures.

The code of conduct must prohibit a conflict of interest with the responsibilities of an agent or employee of an institution, with respect to such loans, and include the provisions set forth in the HEOA related to conflicts. The law further specifies that the code shall be displayed prominently on the institution's website and that all institutional agents or employees with responsibilities related to such loans be annually informed of the provisions of the code of conduct.

GCC hereby adopts the following as the code of conduct related to student loan activities and will annually inform all GCC agents or employees with responsibilities for student loan activities and decisions of the provisions of this code.

Revenue-Sharing Arrangements with any Lenders

The College will not enter into any revenue-sharing arrangements with any lender.

Revenue-sharing is defined as an arrangement between the College and a lender under which (a) a lender provides or issues a loan to students attending the College or to their families; and (b) the College recommends the lender or the loan products of the lender and in exchange, the lender pay a fee or provides other material benefits, including revenue for profit sharing, to the College or its employees.


No employee of the College who works in the financial aid office of the College or who otherwise has responsibilities with respect to education loans, or an agent who has responsibilities with respect to education loans, shall solicit or accept any gift from a lender, guarantor, or servicer of education loans. A gift to a family member or an employee or to any other individual based on that individual's relationship with the employee shall be considered a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and the employee has reason to believe the gift was given because of the employee's position at the College. (For the purpose of this policy, a "relative" is defined as an individual with whom an employee has a relationship by blood, marriage, adoption, domestic partnership, or other personal relationship in which objectivity might be impaired.)

The term "gift" means any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than a de minimums amount. The term includes a gift of services, transportation, lodging, or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred. The term "gift" does not include the following:

  1. Standard materials, activities, or programs on issues related to a loan, default, aversion, default prevention, or financial literacy, such as a brochure, a workshop, or training.
  2. Food, refreshments, training or informational material furnished to the College 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 College, if such training contributes to the professional development of the College's employees.
  3. Favorable terms, conditions, and borrower benefits on an education loan provided to a student employed by the College or an employee who is the parent of a student if such terms, conditions, or benefits are comparable to those provided to all students of the College and are not provided because of the student's or parent's employment with the College.
  4. Entrance and exit counseling services provided to borrowers to meet the College's responsibilities for entrance and exit counseling as required by law, as long as the College's staff are in control of the counseling, and such counseling does not promote the products or services of any specific lender.
  5. 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.
  6. State education grants, scholarships or financial aid funds administered by or on behalf of a State.
  7. Token awards from professional associations (state, regional, or national) that recognize professional milestones or extraordinary service to parents and students, or scholarships for conference attendance or other professional development opportunities.

Contracting Arrangements

No employee shall accept from any lender or affiliate of any lender 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 services to a lender or on behalf of a lender relating to education loans.

Interaction with Borrowers

The College will not assign a borrower's FFELP loan, through award packaging or other methods, to a particular lender. The College will not refuse to certify or delay certification of any federal loan based on the borrower's selection or a particular lender or guaranty agency. The College will not assign a student's private student loan to a particular lender, or refuse to certify or delay certification of any private loan, based upon the borrower's selection of a lender or guaranty agency. The College does not utilize a preferred lender list.

Private Loans

The College will not request or accept from any lender any offer of funds to be used for private education loans, including funds for an opportunity pool loan, to students in exchange for the College providing concessions or promises regarding providing the lender with a specified number of federal loans, a specified federal loan volume or a preferred lender arrangement for federal loans.

Staffing Assistance

The college will not request or accept from any lender any assistance with call center staffing or financial aid office staffing. Nothing in this section, however, prevents the College from accepting assistance from a lender related to professional development training for its staff; providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials; or staffing services on a short-term, nonrecurring basis to assist the College with financial aid-related functions during emergencies including state declared or federally declared natural disasters, federally declared national disasters, and other localized disasters and emergencies identified by the Secretary of Education.

Advisory Board Compensation

No employee who serves on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors may receive anything of value from the lender, guarantor, or group of lenders or guarantors in return for that service.

Conflict of Interest

No employee shall have a conflict of interest with respect to any education loan or other student financial aid for which the employee has responsibility.  Employees within the GCC 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.

No employee may process any transaction related to his/her own personal financial aid eligibility or that of a relative.

Information Provided by the Financial Aid Office

GCC ensures:

  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 a breakdown of individual components of GCC's cost of attendance, designating all potential billable charges, a clear identification of each award indicating type of gift aid, work or loan and standard terminology and definitions.
  3. All required consumer information is displayed in a prominent location on the institutional web site and in any printed materials, easily identified and found and labeled as "Consumer Information."
  4. Financial aid employees will disclose to GCC any involvement, interest in, or potential conflict of interest with any entity with which the institutional has a business relationship.


Statement of Ethical Principles

The primary goal of the financial aid professional is to help students achieve their educational goals through financial support and

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.