Financial Aid: Code of Conduct
Degree-seeking students who are recipients of need-based financial aid should note the following.
The Higher Education Opportunity Act (HEOA) requires institutions of higher education participating in the administration of educational loan programs to develop and publish a code of conduct that prohibits conflicts of interest for financial aid personnel. In compliance with this law, the Art Institute of Chicago d/b/a the School of the Art Institute of Chicago (SAIC) adopted this Financial Aid Code of Conduct. Any SAIC officer, employee, or agent who has responsibilities with respect to student financial aid must comply with this Financial Aid Code of Conduct as set forth below.
- Ban on revenue sharing arrangements
SAIC shall not enter into any revenue-sharing arrangements with any lender. SAIC shall not accept any fee or other material benefit in exchange for recommending a lender to its students.
- Gift ban
No SAIC officer, employee or agent with student financial aid responsibilities shall solicit or accept a gift from a lender, guarantor, or servicer of educational loans. For purposes of this prohibition, the term "gift" means any gratuity, favor, discount, entertainment, hospitality, loan, or other item having a monetary value of more than a de minimus amount, but does not include:
- standard materials, activities or programs on issues related to a loan or financial literacy, such as a brochure, a workshop or training;
- food, refreshments, training or informational materials furnished to an SAIC officer, employee or agent as an integral part of a training session that is designed to improve SAIC's services;
- favorable terms, conditions or borrower benefits provided to a student employed by SAIC if comparable terms are provided to all SAIC students;
- entrance and exit counseling services provided to borrowers as long as SAIC's staff is in control of the counseling and the counseling does not promote one specific lender;
- philanthropic contributions to an institution unrelated to educational loans; and
- state educational grants, scholarships or financial funds administered on behalf of a state.
- Contracting arrangements prohibited
A SAIC officer, employee or agent with student financial aid responsibilities shall not accept from any lender or affiliate of any lender any fee, payment, 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 educational loans.
- Interaction with borrowers
SAIC shall not automatically assign a particular lender to any first-time borrower and shall not refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.
- Prohibition on offers of funds for private loans
SAIC shall not request or accept from any lender any offer of funds to be used for private educational loans, including funds for an opportunity pool loan, in exchange for SAIC providing the lender with a specified number or volume of federal loans or a preferred lender arrangement for such loans.
- Ban on staffing assistance
SAIC shall not request or accept from any lender any assistance with call center staffing or Student Financial services Office staffing. Lenders, however, may provide professional development training to financial aid administrators, educational advising materials to borrowers provided that the materials disclose that the lender prepared them, or assistance in short-term, non-recurring state or federally-declared natural disasters.
- Advisory board compensation
All employees with financial aid responsibilities shall be prohibited from receiving anything of value from a lender or guarantor in return for service on its advisory board except that an employee may be reimbursed for reasonable expenses incurred in such service.
Violations of this Code of Conduct may result in disciplinary action, up to and including, termination of employment.
- Complaints and concerns
Any person may submit a complaint or concern about matters covered by this Code of Conduct by:
- Leaving a message on the complaints hotline at 443.3320; or
- Writing to SAIC's General Counsel at the following address: General Counsel—Attn: Complaints, The Art Institute of Chicago, 111 S. Michigan Avenue, Chicago, IL 60603; or
- Writing to the Chairman of the Art Institute's Audit Committee at the following address: Chair, Audit Committee—Attn: Complaints, The Art Institute of Chicago, 111 S. Michigan Avenue, Chicago, IL 60603
Any complaint or concern received will be handled as set forth in the Art Institute of Chicago's Whistleblower Policy.