Student Lending Code of Conduct

Excelsior University maintains a code of conduct governing provision and administration of student loans. Consistent with requirements of the obligations codified in the New York State Student Lending Accountability, Transparency and Enforcement (SLATE) Act enacted on May 29, 2007, and the requirements of the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008, Excelsior University prohibits:

• Revenue sharing arrangements with any lender. We will not promote or recommend any lender in exchange for a fee or other material benefit from a lender.
• The solicitation or acceptance of gifts from a lender, guarantor or servicer by anyone with responsibilities with respect to loans at the institution, including administrative/executive officials with decision-making authority over financial aid operations. This prohibition extends to our staff members’ families (including staff members and spouses; parent and stepparent; sibling or step- sibling; child or step-child; and grandchild or step-grandchild; as well as the child’s spouse and sibling’s spouse).
• Employees or agents of a lender from identifying themselves as our employee, whether directly or by implication, to students, parents or any person seeking information about Excelsior University.
• The assignment of a first-time borrower’s loan to a particular lender, or refusing to certify/originate or otherwise delay certification/origination of any loan, regardless of the lender or guaranty agency the borrower selects.
• The acceptance of any funds to be used for private/alternative education loans in exchange for the institution providing concessions to the private lender.
• Requesting or accepting assistance with financial aid office staffing from any lender.
• Any employee with responsibilities with respect to financial assistance at the institution, including administrative/executive officials with decision-making authority over financial aid operations, who serves on an advisory board or commission of a lender or guarantor may not accept anything of value from the lender or guarantor, except reimbursement for the reasonable expenses of serving on the board or commission. A financial aid office staff member wishing to serve on an advisory board must seek prior approval from his or her supervisor.

The foregoing prohibitions involve technical definitions which can be found by referring to the applicable state and federal law (i.e., Article 13-B of the New York State Education Law, and Section 493 of the Higher Education Opportunity Act.)

Excelsior employees with responsibilities involving student financial aid, including administrative/executive officials with decision-making authority over financial aid operations, are to be informed of the provisions of the Code of Conduct on an annual basis.

Sanctions
Any University employee who violates this Code of Conduct may be subject to discipline, up to and including termination of employment.