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Financial Aid Code of Conduct

This policy applies to ICOHS staff and faculty, and it prohibits a conflict of interest with their responsibilities with respect to Title IV loans. The policy is part of the ICOHS commitment to the highest ethical standards and conduct by its employees.

ICOHS responsibilities:

An institutional financial aid professional is 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 financial aid professional should:

  • Refrain from taking any action for his or her personal interest or benefit;
  • Refrain from awarding financial aid to themselves or their immediate family members.
  • Have a designated person in the institution, handle financial aid for immediate family members, to avoid the appearance of a conflict.
  • Refrain from compiling a preferred lender list.
  • Be transparent, complete, and accurate, do not auto-assign to any particular lenders
  • Refrain from taking any action he or she believes is contrary to law, regulation, or the best interests of the students and parents he or she serves;
  • Do not deny, impede, or unnecessarily delay the borrower’s choice of lender.
  • 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; and
  • Disclose to his or her institution, in such manner as his or her institution may prescribe, any involvement with or interest in any entity involved in any aspect of student financial aid.
  • Award notifications and/or other materials shall have a breakdown of the cost of attendance, all potential billable charges, identification of each award, standard terminology, and definitions, as well as, renewal requirements for each award.
  • All this consumer information will be in a prominent location on our website.
  • Financial aid professional’s need to let the institution know of a potential conflict of interest with any of the institutions business relationships.


The primary goal of the financial aid professional is to help students achieve their educational potential by providing appropriate financial resources. Our members are required to exemplify the highest level of ethical behavior in helping students and families find the best ways to pay for college and demonstrate the highest level of professionalism. We take great pride in our essential task of helping our students and families determine the best ways to meet their educational expenses. The Financial Aid Professional shall:

  • Be committed to removing financial barriers for those who wish to pursue postsecondary learning.
  • Make every effort to assist students with financial need free of charge.
  • Be aware of the issues affecting students and advocate their interests at the institutional, state, and federal levels.
  • Adhere to all applicable laws and regulations.
  • Support efforts to encourage students, as early as the elementary grades, to aspire to and plan for education beyond high school.
  • Always deal with others honestly and fairly, and always act in a manner that creates trust and confidence.
  • Educate students and families through quality consumer information and teach them to responsibly manage expenses and debt.
  • Educate students and their families through quality information that includes transparency and full disclosure on award notices.
  • 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.
  • Will inform all entities of any changes in financial aid programs that could affect student aid eligibility.
  • Provide services that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.
  • Private information provided to the financial aid office by the applicant is protected in accordance with FERPA and the higher education act, section 483 (a) (3) (20 U.S.C. 1090) and state and federal statutes and regulations.
  • 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.
  • FAFSA information is only used for the application, award, and administration of financial aid awarded under title IV of the Higher Education Act.
  • Maintain the highest level of professionalism, reflecting a commitment to the goals of the National Association of Student Financial Aid Administrators.

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