The following memorializes the USC Office of Financial Aid Code of Conduct and Business Practices for Relationships with Lenders (“Code of Conduct”) that should apply in our relationships with any lending institution that is an actual or potential lender to USC students and parents. This Code of Conduct applies to all managers and employees in the University Park Financial Aid Office and all financial aid managers and employees in the professional schools (“Financial Aid Employees”).

  1. No Payments to Financial Aid Officers and Employees: Financial Aid Employees may not accept anything of more than nominal value (less than $50.00 per year or an isolated lunch or dinner) from any lending institution. This standard also applies to gifts, meals and other business courtesies.

  2. No Equity Interests: Financial Aid Employees may not hold any public or private equity interest (e.g., stocks, stock options, warrants or other ownership interests) in any lending institution that is on the university’s lender list. This prohibition does not include any equity interests that are managed by a third party, such as a mutual fund.

  3. Lender Visitation: The Financial Aid Office will maintain a log and record all visits and meetings conducted with lenders. This log will include the names of USC staff and lender representatives who attended the meetings and/or visits, and the nature of the discussion.

  4. Service on an Advisory Board Requires Approval: Financial Aid Employees may not serve on the advisory board of any lending institution without obtaining prior written approval from the Provost or his/her designee. Financial Aid Employees may not receive any reimbursement or other compensation for serving on an approved lending institution advisory board. Lending institutions shall not pay for any travel, food or lodging expenses incurred as a result of service on an advisory board.

  5. No Remuneration to the University: Financial Aid Employees may not accept or receive anything of value from a lending institution on behalf of or as a representative of USC, in exchange for any advantage or consideration given to the lending institution. This prohibition includes, but is not limited to, revenue sharing arrangements, scholarships, reimbursement for printing costs or services, equipment offered at less than fair market value and staffing assistance.

  6. Lender Lists Must Serve Students and Parents: Lender lists must be based solely on the best interests of the students or parents, who may use the list without regard to the financial interests of the university.

  7. Lender List Disclosure: USC will clearly disclose the process and criteria used to select those lending institutions that appear on its lender lists and related brochures or websites. Students must be told that they have the right and ability to select the lending institution of their choice, regardless of the lender lists. Lenders shall be listed alphabetically. The lender lists shall be reviewed annually.

  8. Directing Borrowers to Lenders: Financial Aid Employees may not direct borrowers to particular lenders or refuse or delay loan certifications based on the borrower’s lender choice.

  9. Prohibition on Call Centers: Financial Aid Employees may not retain or otherwise engage any lending institution to staff call centers to respond to financial aid inquiries by USC parents or staff.

  10. Transparency in Employment: Employees of lending institutions must clearly identify that they are employed by a lending institution when interacting with USC students and parents. Employees of lending institutions are not permitted to identify themselves as USC employees to USC students and parents.

  11. Entrance/Exit Counseling: Financial Aid Employees will not engage any lending institution to provide entrance or exit counseling to USC students.

The Provost or his/her designee will review this Code of Conduct and may update or revise it at his/her discretion to ensure that it remains current and consistent with university policy and regulatory requirements.

©2013 University of Southern California