Financial Aid Handbook & Policies
Higher Education Act Standard for School/Lender Relations (P. L. 110-315)
Prohibition Against Remuneration to Western Illinois University
Western will not solicit, accept or agree to accept anything of value from any Lending Institution, Guarantee Agency or Servicer in exchange for any advantage or consideration provided by the Lending Institution related to its student loan activity. This prohibition covers, but is not limited to:
- Revenue Sharing Agreements.
- Any computer hardware for which Western pays below market prices.
- Any computer software used to manage loans unless the software can manage disbursements from all lenders.
- Any printing costs, postage or services.
- This does not prevent Western from soliciting, accepting or agreeing to favorable terms and conditions in which the benefit is made directly to student borrowers.
Prohibition Against Remuneration to Western Illinois Employees
Western will require and enforce that no officer, director, employee or agent of the University will accept anything having a monetary value amount more than a token (nominal) on his or her own behalf or on behalf of another during any 12 month period from, or on behalf of any Lending Institution, Guarantee Agency or Servicer.
This prohibition will include, but not be limited to a ban on any payment or reimbursement from any Lending Institution, Guarantee Agency or Servicer to University employees for lodging, meals, or travel to conferences or training seminars.
This does not preclude any officer, trustee, director, employee or agent of the University from receiving compensation for conducting non-University business with a Lending Institution, Guarantee Agency or Servicer or from accepting compensation that is offered to the general public.
This prohibition does not prevent the University from holding membership in any non-profit professional association.
Prohibition of Gifts
No person at Western involved in any aspect of student loans shall solicit or accept any gift from a Lender, Guarantor, or Servicer of student loans. This includes but is not limited to financial aid administrators, supervisors of financial aid administrators, Business Office personnel who deal with loans, anyone who otherwise has responsibility or authority over the financial aid operation and anyone who has anything to do with the decision making process regarding student loans to include officers and trustees for any of the above. Further, this would include gifts to family members if:
- the gift is given with the knowledge and acquiescence of the officer, trustee or university employee and the officer, trustee or university employee has reason to believe the gift was given because of the official position of said officer, trustee or university employee.
Gifts are defined as but not limited to:
- Any type of gratuity, favor, discount, entertainment, hospitality, loan or other item having more than a token value. The term 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 been incurred.
The following items are not considered as gifts:
- Standard material, activities or programs on issues related to a loan, default aversion, default prevention or financial literacy, such as a brochure, a workshop or training.
- Food, refreshments, training or informational material furnished to any officer, trustee or university employee as an integral part of a training session that is designed to improve the service of a Lender, Guarantor or Servicer of education loans to the institution, if such training contributes to the professional development of the officer, trustee or employee.
- Favorable terms, conditions and borrower benefits on an education loan provided to a student employed by the institution if such terms, conditions or benefits are similar to those provided to all students of the institution.
Entrance and exit counseling services provided to borrowers in meeting the institution's responsibilities for entrance and exit counseling as required as long as:
- The institution's staff is in control of the counseling and such counseling does not promote the products or services of any specific lender.
- Philanthropic contributions that are unrelated to education loans or any contribution not made in exchange for any advantage related to education loans.
- State education grants, scholarships or financial aid funds administered by or on behalf of a State.
Ban on Gifts to Family Members
Gifts to family members of any officer, trustee, director or university employee will be considered a gift to said officer, trustee, director or university employee if:
the gift is given with the knowledge and acquiescence of the officer, trustee, director or university employee and the officer, trustee, director or university employee has reason to believe the gift was given because of the official position of said officer, trustee, director or university employee.
Limits of University Employees Participating on Lender Advisory Boards
Western will require and enforce that no officer, trustee, director or employee of the University from receiving any remuneration for serving as a member or participant of an advisory board of any Lending Institution, Guarantee Agency or Servicer or in receiving any reimbursement of expenses from said participation.
This does not preclude any officer, trustee, director or employee from participating on any lender advisory board that is unrelated to student loans.
This does not preclude any Western employee not involved in the affairs of the University's Financial Aid Office from serving on the Board of Directors of a publicly traded or privately held company.
Contracting Arrangements Prohibited
Any officer, trustee, director or employee is prohibited from accepting any payments of any kind from a lender in exchange for any type of consulting services related to educational loans. Further:
- This does not prevent anyone else in the institution who has nothing to do with student loans from entering into these agreements.
- This does not prevent anyone not employed in the Financial Aid Office who has "some" responsibility for student loans from entering into these agreements if that individual in writing, recuses him or herself from any decision regarding educational loans.
- This does not prevent anybody from serving on a board of directors or trustee of an institution if the individual recuses him or herself from any decision regarding educational loans.
Revenue Sharing Agreements Prohibited
Western will not enter into any revenue sharing agreement in which:
a lender provides or issues a loan that is made, insured or guaranteed under this title to students attending the institution or to the families of such students; and the institution recommends the lender and in exchange the lender pays a fee or provides other material benefits.
Prohibition on Offers of Funds for Private Loans
Western will not request or accept any agreement or offer of funds for private loans in exchange for concessions or promises of:
- A specified number of loans made, insured, or guaranteed.
- A specified loan volume.
- A preferred lender arrangement.
Ban on Staffing Assistance
Western will not request or accept from any lender any assistance with call center staffing or financial aid office staffing.
This does not include:
- Professional development training for financial aid administrators.
- Educational counseling materials, financial literacy materials, or debt management materials to borrowers provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials. Staffing services on a short-term, nonrecurring basis to assist the institution with financial aid related functions during emergencies, including State or federally declared natural disasters.