The Cleveland Institute of Music Financial Aid Office has adopted the NASFAA (National Association of Student Financial Aid Administrators) statement of Ethical Principles as its Code of Ethics and Code of Conduct.
Code of Ethics
The Statement of Ethical Principles provides that the primary goal of the Cleveland Institute of Music's Financial Aid Office is to help students achieve their educational potential by providing appropriate financial resources. To this end, this Statement provides that the CIM Financial Aid Office professional shall:
- Be committed to removing financial barriers for those who wish to pursue post secondary learning.
- Make every effort to assist students with financial need.
- Be aware of the issues affecting students and advocate their interest at the institutional, state, and federal levels.
- Support efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school.
- Educate students and families through quality consumer information.
- Respect the dignity and protect the privacy of students, and ensure the confidentiality of student records and personal circumstances.
- Ensure equity by applying all need analysis formulas consistently across the institution's full population of student financial aid applicants.
- Provide services that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.
- Recognize the need for professional development and continuing education opportunities.
- Promote the free expression of ideas and opinions, and foster respect for diverse viewpoints within the profession.
- Commit to the highest level of ethical behavior and refrain from conflict of interest or the perception thereof.
- Maintain the highest level of professionalism, reflecting a commitment to the goals of the financial aid profession.
Code of Conduct
In consideration of the complexity of the tasks confronting institutional financial aid professionals, the NASFAA Board of Directors has promulgated this Code of Conduct to further guidance respecting the Statement of Ethical Principles. The Code is intended to help guide financial aid professionals in carrying out these obligations, particularly with regard to ensuring transparency in the administration of the student financial aid programs, and to avoid the harm that may arise from actual, potential, or perceived conflicts of interest.
Financial Aid Professionals are expected to always maintain exemplary standards of professional conduct in all aspects of carrying out his or her responsibilities, specifically including all dealings with any entities involved in any manner in student financial aid, regardless of whether such entities are involved in a government sponsored, subsidized, or regulated activity. In doing so, a CIM financial aid professional will:
- Refrain from taking any action for his or her personal benefit.
- Refrain from taking any action he or she believes in contrary to law, regulation, or the best interests of the students and parents he or she serves.
- Ensure that the information he or she provides is accurate, unbiased, and does not reflect any preference arising from actual or potential personal gain.
- Be objective in making decisions and advising his or her institution regarding relationships with any entity involved in any aspect of student financial aid.
- Refrain from soliciting or accepting anything of other than nominal value from any entity (other than an institution of higher education or a governmental entity such as the U.S. Department of Education) involved in the making, holding, consolidating or processing of any student loans, including anything of value (including reimbursement of expenses) for serving on an advisory body or as part of a training activity of or sponsored by any such entity.
- Disclose to his or her institution, in such a manner as his or her institution may prescribe, any involvement with or interest in any entity involved in any aspect of student financial aid.
Preferred Lender List/Student Loan Practices
The Cleveland Institute of Music participates in the William D. Ford Federal Direct Loan Program, which includes the Direct Subsidized and Direct Unsubsidized Student Loans, the Direct Graduate PLUS Loans, and the Direct Parent PLUS Loans. CIM also processes private loans for students on an as needed basis. To comply with the 2008 Higher Education Opportunity Act (the "Act"), CIM adopts the following Code of Conduct to provide guidance to CIM employees in insuring the integrity of the student aid process and in ensuring ethical conduct of CIM employees in regard to student loan practices. This Code of Conduct is applicable to all CIM employees and agents, and specifically, the school's Financial Aid Office, the Business Office, and any other applicable CIM offices.
- Revenue Sharing
The term "revenue-sharing arrangement" means an arrangement between an institution and a lender that - (i) a lender provides or issues a loan that is made, insured, or guaranteed to students under the Act 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.
CIM and its employees will not enter into any type of revenue-sharing arrangement with any lender, guarantor or servicer. All loans are processed without regard to lender or mode of transmission (i.e., electronic or paper). CIM will neither recommend a private loan lender nor accept material benefits including revenue or profit sharing to the University, an officer, or an employee of the University or an agent.
Employees of the Financial Aid Office and the Business Office are prohibited from soliciting or accepting any gift from a lender, guarantor, or servicer of education loans.
- Gifts include any gratuity, favor, discount, entertainment, hospitality, loan or other similar item having a monetary value of more than a de minimus amount. This 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 incurred. However, gifts do not include those specific exemption set forth in the Act (20 U.S.C. Section 1094(e)(2)(B)(ii)).
- Gifts to family members of a CIM employee are considered to be a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and there is reason to believe the gift was given because of the official position of that employee.
- Contracting Arrangements
Employees of the Financial Aid Office and the Business Office shall not accept from any lender, or affiliate of any lender, any fee, payment, or other financial benefit (including opportunity to purchase stock) as compensation for any consulting arrangement or other contract to provide services to a lender, or on behalf of a lender, relating to education loans.
- Preferred Lender Status
CIM participates in the William D. Ford Federal Direct Loan Program, which provides student and parent loans through the United States Department of Education. Lenders in the private student loan industry will not be given a preferred status. CIM will not produce a preferred lender list that gives any lender an advantage in securing business from CIM students. Any CIM preferred lender list will clearly and fully disclose the criteria and process used by CIM to select preferred lenders. Further, students will be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.
- Interaction with Borrowers
CIM will not assign a borrower's private student loan to a particular lender; all decisions will be made by the borrower in his/her independent review of borrower benefits and lender services. Further, CIM will not refuse to certify, or delay certification of, any loan based on the borrower's selection of a particular lender or guaranty agency.
- Opportunity Pool Loan
CIM will not request or accept from any lender any offer of funds to be used for private education loans (defined in section 140 of the Truth in Lending Act) including funds for an opportunity pool loan in exchange for CIM providing concessions or promises regarding providing the lender with a specified number of loans made, insured or guaranteed; a specified loan volume of such loans; or a preferred lender arrangement for such loans.
- Staffing Assistance
CIM will not request or accept from any lender, guarantor, or servicer of student loans any assistance with call center staffing or financial aid office staffing. CIM will also prohibit employees, representatives, or agents of any lender, guarantor, or servicer of student's loans from identifying themselves to students of CIM or their parents as employees, representatives, or agents of CIM.
- Advisory Board Compensation
Employees of the Financial Aid Office and the Business Office who serve on an advisory board, commission, or group established by a lender, guarantor, or group of lenders or guarantors, are prohibited from receiving anything of value from the lender, guarantor, or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission, or group. Any employee who serves on such an advisory board, commission or group described above shall recuse himself or herself from any discussions regarding CIM's financial aid operations.
- Use of Logo or Name by Lenders
No lender, guarantor, or group of lenders or guarantors, shall be permitted to use the name or logo of CIM, or other words, pictures, or symbols readily identified with or marks of CIM in the marketing of private educational loans to the students attending CIM in any way that implies that CIM endorses the private educational loans offered by the lender, guarantor, or group of lenders or guarantors.