Code of Conduct
Dependency Status Determination
Loan Default, Enrollment Status, and Disbursement
Return of Title IV Policy

Code of Conduct
The purpose of this policy is to establish standards of conduct for employees within Cleary University or Cleary University-affiliated organizations involved in or having responsibilities for student educational loans.

Lender List: Cleary University does not have or refer students to any private lender list. Students are left to their own resources to find a private lender if they have additional need for funds over and above what is offered through the federal direct lending program.

The financial aid staff will not deny or otherwise impede a borrower’s choice of lender or cause unnecessary delay in loan certification for borrowers who choose a lender that is not included on the lender list.

The financial aid staff will not assign a particular loan lender to a first-time borrower.  

Private Educational Loans: The University will not request or accept from any lender an offer of funds to be used for private education loans including funds for an opportunity pool loan, to students in exchange for the University providing concessions or promises regarding providing the lender with 1) a specified number of federal loans; 2) a specified federal loan volume; 3) or a preferred lender arrangement for federal loans.     

Revenue Sharing: The University will not enter into any revenue-sharing arrangement with any student loan lender.

Co-Branding: The University will not permit a private educational lender to use the University’s name, emblem, mascot, logo, or any other words, pictures, or symbols associated with the University to imply endorsement of private educational loans by that lender.

Staffing Assistance:The University will not request or accept from a lender assistance with call center staffing or staffing within the Financial Aid Office that would not be acceptable under federal guidelines.

Gifts: Officers, employees, or agents of the University who have responsibilities with respect to educational loans, shall not solicit or accept gifts having a monetary value of more than a de minimums (token) amount. Definition of gifts including but not limited to gratuity, entertainment, hospitality, gift (unpaid) of  services, transportation, lodging, or meals.

Exceptions to the definition above that are approved items: standard material, activities, or programs on issues related to a loan default aversion, default prevention, or financial literacy such as a brochure, workshop, or training. Food, refreshments, training, or informational material furnished to an officer or employee as an integral part of a training session designed to improve services of a lender, guarantor, or servicer of educational loans, if training contributes to the professional development of the officer, employee, or agent of the institution. See federal regulations for additional approved exceptions.

Dependency Status Determination
Dependency status is the determination of who has the primary responsibility of contributing toward a student’s educational expenses. Students are classified as either dependent or independent. Dependent students, usually under the age of 24, have access to parental support and must include parental information on their aid application. Students are independent if they meet one or more of the criteria below:

• 24 years of age or older
• Married
• Enrolled in a graduate or professional program (beyond a bachelor's degree)
• Have legal dependents, other than a spouse
• Were orphaned or a ward of the court since turning age 13
• Have been in foster care since age 13
• Are a veteran of the U.S. Armed Forces who served on active duty
• Currently serving on active duty in the U.S. Armed Forces
• Both of the students’ parents are deceased from the age of 13
• A legally emancipated minor as determined by a court
• Currently homeless or at risk of being homeless as determined by a high school counselor or assistance agency

Loan Default, Enrollment Status, and Disbursement
Loan Default
Students found in default of any Title IV loans or owing a Title IV refund to any college will not be eligible to receive any aid funds. Official academic transcripts will not be released to students who are found to be in default of student loans.

Enrollment Status
To participate in most aid programs, students must enroll for a minimum of six credit hours per quarter in a program leading to a degree. See enrollment classifications below:

After 60% of the term has passed, no credit is available.

Evidence of Attendance Policy for Financial Aid Purposes

Evidence of attendance in enrolled classes is required for all University students. Satisdactory evident of attendance is defined as by fulfilling at least one of the following:

·        Participating in the eCleary discussion forum

·        Completing an eCleary quiz

·        Uploading an assignment in an eCleary classroom

This policy applies for all classes regardless of delivery format. Evidence of attendance is tracked by the eCleary course management software. Failure to meet this requirement may result in loss of eligibility for certain types of student financial aid. 

Disbursement
Aid funds are posted for an eligible student on a quarterly basis once the aid file is complete, but not more than 10 days prior to the applicable term. Grants and scholarships for each term are posted to the student account after the aid file is complete and the student is registered for classes. Loan proceeds are not posted to the student account until they are actually received from the student's lender. It is the policy of the Financial Aid Office to divide awards into thirds to correspond to the three quarters of the regular academic year: Fall, Winter, and Spring. When adding a Summer term, aid will be divided evenly between four terms. The University will apply the following priorities when refunds must be made to Title IV (Federal) aid programs:

• Federal Unsubsidized Direct Loans
• Federal Subsidized Direct Loans
• Federal PLUS Loans
• Federal PELL Grants
• ACG
• SMART Grant
• Federal Supplemental Educational Opportunity Grant (SEOG)
• Michigan Tuition Grant/Competitive Scholarship (MTG/MCS)
• Private and Institutional Scholarships

Return of Title IV Funds Policy
This policy applies when students receiving financial aid cease to be enrolled.

• Changing Schedule: If a student decides to change his or her schedule (drop/add or change to a different section of the same class), he or she must complete a drop/add form through his or her academic advisor. This must be done regardless of whether or not the student has attended the class(es) for which he or she has registered.
• Financial Aid Recipients: If a student is receiving financial aid (Title IV Funds), he or she may receive a credit if he or she drop or withdraw from all of his or her classes before the completion of 60% of the term. Credit is based on the date the student’s completed drop/add form is received by the Business Office, not on the last date the student attended class. Therefore, it is important that the student completes and turns in the drop/add form as soon as possible once he or she has decided to change his or her schedule. Failure to attend class does not change enrollment status or absolve the student from financial or academic responsibilities.
• Return of Title IV funds for classes on the standard schedule will be computed using the Department of Education R2T4 approved website which calculates the number of days that have passed in the term over the total number of days in the term. The total number of days in the term includes break time and weekends. A grade of "W" will be given for any class from which a student withdraws after the first week of class.

Refund Distribution as Prescribed by Federal Regulation for Title IV Funds

In most cases, withdrawing from a class(es) does not mean that a student will actually receive a cash refund of the monies paid to his or her account. The student may, in fact, owe the government some of the money that was disbursed to him or her at the beginning of the term. The funds must be returned in the following order of refund source priority:

• Unsubsidized Federal Direct Loans
• Subsidized Federal Direct Loans
• Federal PLUS Direct Loans
• Federal Pell Grants
• Academic Competitiveness Grant
• National SMART Grant
• Federal Supplemental Educational Opportunity Grants (SEOG)
• Other Title IV Programs
• Other federal sources
• Other state, private or institutional aid
• The student

Following is the Return of Title IV Funds for Cleary University financial aid students. Federal return of funds is prorated up to 60% of the program. Please direct any questions about the policy to financial aid personnel.

To determine the amount of aid that will be returned to the federal Title IV programs, the number of days from the student’s term start date to his or her drop date will be calculated. That number will be the numerator and the total number of days in the term will be the denominator. The result is the percentage of federal funds that Cleary University will apply to the student’s account. In most cases, the Financial Aid Office will return aid funds to appropriate sources as required. In the case where the student has received a refund of a Title IV Grant, such as a Pell Grant, and the calculation resulted in the student owing a repayment of their Pell Grant funds, he or she is responsible for repayment of 50% of his or her portion of the obligation. Grant overpayments to the student are subject to either immediate repayment to the institution or a satisfactory repayment arrangement. The overpayment may be also sent directly to the Department of Education Collections department. Note: Cleary's Institutional Refund Policy is different and not related to Return of Title IV funds. For information about the Institutional Refund Policy, please see the Business Office.

The United States Department of Education requires students receiving financial aid to maintain satisfactory academic progress. The policy, monitored by the Records Office and the Financial Aid Office, is divided into three components: duration of eligibility, hours attempted, and grade point average. A student must be making progress in all three areas to continue financial aid eligibility. Click here for the Cleary University policy which complies with this requirement.

Duration of Eligibility

Eligibility is based on a student's entire academic record, whether or not financial aid was given during any quarter. Accountability starts with the student's entry date at Cleary University and would also include transfer hours from other institutions. According to federal regulation 668.16 (e)(ii)(B), enacted April 29, 1994, the time to complete the educational program length, as a full-time student, may not exceed more than 150% of the published length. This means that a four-year program must be completed by the sixth year (4 X 150% = 6). Total credits allowed for undergraduate studies would be no more than 270 credits (180 x 1.5.).

Hours Attempted

Effective September 1999, each new, continuing, or reactivating student must successfully complete 67% of the hours attempted during each evaluation period. The evaluation period will consist of three terms, one academic year 668.16 (e)(c). If by the end of the evaluation period the student has not successfully completed at least 67% of the hours for which he/she officially registered, financial aid for the following term may be cancelled.

Examples of a 67% completion rate during a one-term period would be:

• If you registered for 12 credits each term, you would need to complete at least 8 credits. If you registered for 9 credits each term, you would need to complete at least 6 credits.
• If you registered for 6 credits each term, you would need to complete at least 4 credits.

For financial aid purposes, the following grades will be counted as unsatisfactory completion: I, E, W, NC, and IW. Retaken classes are considered as attempted courses when determining completion rates. Note: Incompletes (I) must be converted to a letter grade. Your transcript will be evaluated again after an I is converted to a letter grade.

Grade Point Average

A student's cumulative grade point average (GPA), calculated from all classes taken and all grades received while attending Cleary University, may not drop below 2.0 for more than three consecutive terms. Graduate students must obtain at least a 3.0 GPA after 6 consecutive terms.

All students eligible for the Michigan Tuition Grant can receive the grant for a maximum of 15 terms at full-time status.

Effective with the beginning of the 1998-99 award year, those students who first received Student Financial Assistance (SFA) program funds, must have either a C average or its equivalent, or have academic standing consistent with the requirements for graduation from the program at the end of the second academic year.

Academic Dismissal

A student receiving financial aid who has been dismissed for academic reasons must make an appointment with the Financial Aid Office to determine eligibility for reinstatement of financial aid. If a student is found to be ineligible for aid based on a prior evaluation period, and a financial award for the following term is made, the award may be cancelled.

Regaining Eligibility

Unless unusual circumstances exist, students denied aid because the required number of credits was not successfully completed for the period aid was received must complete the necessary course work at their own expense before being considered for future aid. This applies to students who have not filed an appeal for reinstatement of aid. Students denied aid because of GPA must bring their averages to the required minimum to regain eligibility. Aid granted after reinstatement will be based on funds available at the time.

Appeal Procedure – Exceptional Circumstances

Students denied receipt of aid because of failure to make academic progress can appeal the decision by filing a petition. A written appeal outlining the reasons for failure to meet the standards, as well as appropriate documentation, will be required. It is helpful if you outline how your situation has changed and the steps you have taken to correct the situation. You may address the appeal to the Director of Financial Aid. The appeal will be presented to the Probation Committee.

For questions or more information, contact the Financial Aid Office, at 517.338.3015.

The above policy is based on Title IV Federal Regulation 668.16(e)(ii)(B) through (D).