Financial Aid Policies

As a participant in federal loan programs, Bank Street College is required to develop, administer, and enforce a financial aid code of conduct applicable to the College’s officers, employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. Bank Street College of Education’s Code of Conduct Related to Student Loan Activities fulfills these requirements and applies to certain transactions and activities related to student lending and financial aid matters. Furthermore, Bank Street College of Education also adheres to the Student Lending, Accountability, Transparency and Enforcement (SLATE) Act under New York State law, which applies not only to the College’s officers, employees and trustees, but also to the College’s agents and contractors.

In addition, the financial aid professional at Bank Street College of Education 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.

Revenue Sharing Prohibition: Bank Street College of Education employees are prohibited from receiving anything of value from any lending institution in exchange for any advantage sought by the lending institution.

Gift and Trip Prohibition: Bank Street College of Education employees are prohibited from taking anything of more than nominal value from any lending institution. This includes a prohibition on trips for financial aid officers and other college officials paid for by lenders.

Advisory Board Compensation Rules: Bank Street College of Education employees are prohibited from receiving anything of value for serving on the advisory board of any lending institution.

Staffing Assistance/Call-Center Prohibition: Bank Street College of Education employees are prohibited from accepting from any lender any assistance with call center staffing or financial aid office staffing, except that a lender may provide professional development training, educational counseling materials  (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, nonrecurring basis during emergencies or disasters.

Consulting/Contracting Arrangement Prohibition: Bank Street College of Education employees are prohibited from accepting from any lender or affiliate of any lender any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.

Assigning of Lender to First-Time Borrower Prohibition: Bank Street College of Education Office of Financial Aid will not, for any first-time borrower, assign, through award packaging or other methods, the borrower’s loan to a particular lender or refuse to certify, or delay certification of, any loan based on the borrower’s selection of a particular lender or guaranty agency.

Preferred Lender Lists: If Bank Street College of Education were to use a preferred lender list, the following standards shall be observed and maintained:

• A preferred lender list, if offered, will be based solely on the best interests of the students who may use the list without regard to financial interests of Bank Street College of Education.
• A preferred lender list, if offered, will have at least three or more unaffiliated lenders.
• A preferred lender list, if offered, will clearly and fully disclose the criteria and process used by Bank Street College of Education to select the lenders on the list. Students will be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.
• Lenders listed on a preferred lender list, if it is offered, must first disclose if the lender has an agreement to sell its loans to another lender. No lender will be listed if the lender bargains to be on the list with respect to a certain type of loan by providing benefits to Bank Street College of Education as to another type of loan.
• A preferred lender list, if offered, will provide comparative information on borrower benefits offered by all lenders, including, but not limited to, lenders’ interest rates and loan terms and conditions.
• Bank Street College of Education will endeavor to select lenders with the best borrower benefits, including, but not limited to, lenders’ interest rates and loan terms and conditions, for its preferred lender list, if offered.
• Bank Street College of Education will annually update its preferred lender list if it is offered.
• Bank Street College of Education will not be involved with any lender that  undertakes philanthropic activities in exchange for federal student loan applications, volume, or placement on a school’s preferred lender list

The U.S. Department of Education requires every postsecondary institution receiving federal funds (Title IV) to have an academic progress policy that is used to determine eligibility for and continued receipt of federal funds. The Satisfactory Academic Progress (SAP) policy has two components. First, the students are required to maintain a specified cumulative GPA. Second, they must complete a specified percentage of all courses attempted. Bank Street College also uses this standard to renew/award all aid administered by the College.

Students must make satisfactory academic progress toward their degree in order to maintain eligibility for financial aid programs. In addition to meeting all standards of Satisfactory Academic Achievement, students must earn a minimum number of credits per year at a pace sufficient to complete all degree requirements within five years.

To make satisfactory academic progress for financial aid, students must:

• Achieve a GPA of at least 3.0 each term at the College and maintain academic standing consistent with the requirements for graduation.
• Earn credits towards their degree according to the following standards:

Because the year is measured from July 1 through June 30, a student who first takes a class as a matriculated student in either Spring or Summer 1 would be required to complete only one credit rather than four credits.

A student’s complete academic record will be reviewed annually, generally in July, to ensure that the student is meeting each of the above standards of progress. All courses that appear on a student’s permanent academic record count toward progress even if the student received no financial aid for those semesters.

Measuring Satisfactory Academic Progress:

• Withdrawals recorded on the student’s permanent record will not count toward credits completed/earned and could adversely affect the student’s ability to meet the satisfactory progress standards. Changes to the student’s enrollment record caused by retroactive “non-punitive” administrative withdrawal activity can result in the student having to repay the financial aid that he or she received that semester/term.
• Incomplete Grades: The student’s cumulative record of credits includes any course in which the student receives an incomplete grade. An incomplete course cannot be counted in the student’s completed/earned credits until he or she has received a completion grade. An incomplete grade could keep a student from achieving SAP. The recording of a successful completion grade within a semester/term that brings the accumulated credits up to the satisfactory progress standard will restore eligibility for this and subsequent semesters/terms within the academic year.
• Repeated Courses: Successfully completed courses will be counted toward completed/earned credits.
• Waiving a Course Requirement: Courses waived due to sufficient formal academic study in an area are not counted as completed/earned credits.

Treatment of Nonstandard Situations:

• Readmitted Students: Upon readmission after a period of non-enrollment, the student will be eligible for financial aid for terms in the academic year of readmission and will be measured for continued eligibility against the appropriate year’s satisfactory progress standards.
• Transfer Students: A transfer student will be treated like a new student for measuring satisfactory academic progress; transfer credits accepted toward the degree will be counted as credits completed/earned.
• Second Degree Students: A student enrolled for a second degree will be treated like a new student for measuring satisfactory academic progress; the credits accepted toward the second degree will be counted as credits completed/earned.
• Change of Major/Change of Degree: If the student changes majors/programs within the same degree or certificate program, or if the student changes his or her educational objective and begins pursuing a different degree without having earned the first degree, the student must complete the academic program within the maximum time frame allowed (five years), unless an exception is granted by the Satisfactory Academic Progress Committee.

Appeal/Probation:

Students who fall beneath the standards required for their degree may appeal to the Satisfactory Academic Progress Committee (SAP Committee) to retain their good standing and eligibility to receive financial aid, if applicable. The appeal will be evaluated for mitigating circumstances resulting from events such as personal illness, injury, personal tragedy, or changes in academic program. Also assessed will be the students’ capability for improving their academic record to again meet the standards of progress. If a student is in poor academic standing because he or she is not completing sufficient credits to be making satisfactory progress toward the degree, the student must establish a “Plan of Study” with the advisor/program director for earning additional credits or completing the coursework that the student has attempted but not finished. The student may be ineligible to register for additional credits until the specified “Plan of Study” has been implemented successfully.

If the appeal is granted based on mitigating circumstances, the student will be given a one-year probationary period to improve his or her academic record to meet the standards of satisfactory progress. If the appeal is granted based on poor academic standing or not completing sufficient credits to be making satisfactory progress toward the degree, the student will be placed on Financial Aid Probation (if on financial aid) and must be making SAP each subsequent payment period or successfully following an academic “Plan of Study.” There is no limit on the number of times a student may follow this appeal procedure.

Reinstatement:

If the student chooses not to appeal or if the appeal is denied, the student may regain eligibility for financial aid by taking an official Leave of Absence from Bank Street College for at least one year. Upon readmittance, the student may receive assistance for the terms of the academic year of readmittance and will be measured against the standards at the end of the annual review for continued eligibility.

Bank Street College of Education under statutory language will not provide a commission, bonus, or other incentive payment based in any part, directly or indirectly, on success in securing enrollments or financial aid to any person or entity engaged in any student recruiting or admission activities or in making decisions regarding awarding Title IV funds.

In addition, Bank Street College of Education is prohibited from making adjustments to compensation for any employee engaged in any student recruiting or admission activities or in making decisions regarding awarding financial aid.

An annual adjustment in a calendar year is acceptable if the institution (Bank Street College of Education) can document that said adjustment is not based upon enrollments.

Multiple adjustments in a calendar year are considered to have been made based upon success in securing enrollments or awarding financial aid if those adjustments create compensation based in any part, directly or indirectly, on securing enrollment or awarding financial aid.

Bank Street College of Education, its contractors, and other entities may make acceptable compensation in the form of profit-sharing payments so long as such payments are not provided to any person who is engaged in student recruitment or admission activity or in making decisions regarding the award of Title IV funds.

Commission, bonus, or other incentive payment is defined as a sum of money or something of value, other than a fixed salary or wages, paid or given to a person or entity for services rendered.

Enrollment is defined as admission or matriculation of a student into an eligible institution.

Securing enrollment or the award of financial aid is defined as activities a person/entity engages in at any point in time through completion of an educational program for the purpose of admission or matriculation of students for any period of time or the award of financial aid to students.

Entity/person engaged in any student recruitment or admission activity or in making decisions about the award of financial aid means any institution or organization that undertakes the recruiting or the admitting of students or that makes decisions about and awards Title IV funds; and

Any person who undertakes recruiting or admitting of students or who makes decisions about and awards Title IV funds, and any higher level employee with responsibility for recruitment or admission of students, or making decisions about awarding Title IV funds.

Bank Street College of Education is prohibited under federal regulations from making any false, erroneous, or misleading statement directly or indirectly to a student, prospective student, member of the public, accrediting agency, state agency, or to the Department of Education.

Misleading statement includes any statement that has the likelihood or tendency to deceive or confuse. A statement is any communication made in writing, visually, orally, or through other means. This includes student testimonials given under duress or because such testimonial was required to participate in a program.

Federal regulations further provide that substantial misrepresentation is any misrepresentation on which the person to whom it was made could reasonably be expected to rely, or has reasonably relied, to that person’s detriment.

The regulations regarding misrepresentation describe misrepresentation with respect to:

• Nature of the education program
• Nature of financial charges
• Employability of graduates
• Relationship with the Department of Education. A Title IV eligible school may not describe its participation in a way that suggests approval or endorsement by the Department of Education of the quality of its educational programs.