System Procedure 1C.0.3 Ethical Practices in Recruitment of Students and Administration of Financial Aid

System Procedures
Chapter 1C - Code of Conduct & Ethics

Part 1. Purpose

Minnesota State Colleges and Universities is committed to ethical practices for the recruitment and matriculation of students at all educational levels.

Part 2. Definitions
For the purposes of this procedure only, the following definitions apply.

Admission
Admission of a student to a college or university includes the recruitment, determination, and matriculation process. This definition refers to admission to the college or university, not to an academic program.

Employee
Any individual employed by Minnesota State, which includes the colleges, universities, and system office, and student workers.

Enrollment Agreement
An agreement between an applicant and college or university regarding their commitment to attend the respective college or university.

Student
An individual applying for admission to, admitted to, or enrolled at a Minnesota State college or university.

Part 3. Ethical Behavior and Compliance

All employees and third parties working on behalf of the college or university shall practice ethical behavior in the enrollment of students including, but not limited to, lead generation, recruitment of students, admissions processing and decision-making, student enrollment and registration, and financial aid (including military benefits and scholarship) determinations and administration. Employees shall help students make thoughtful choices about their futures.

Colleges and universities shall demonstrate ethical behavior and communication throughout the recruitment, enrollment, and financial aid processes for all students, including but not limited to, dual enrollment students, undergraduate students, transfer students, international students, current service members, veterans, and graduate students, whether degree-seeking or not.

All employees of Minnesota State and third parties working on behalf of a college or university shall comply with all Board of Trustees policies, system procedures, federal and state laws, and Department of Defense Memorandums of Understanding. In addition to the Employee Code of Conduct, employees are subject to general standards of conduct for employees and are expected to meet any professional standards of conduct or ethical requirements applicable to their discipline. Colleges and universities must exercise oversight to ensure the adherence to these policies, procedures, and standards throughout the student recruitment and financial aid processes.

Part 4. Recruitment and Matriculation Process

The following activities are commonly part of the recruitment and matriculation process for students:

information sessions,
high school visits,
classroom or group presentations,
open houses,
tabling at fairs,
campus tours,
individual appointments, and
help sessions for applying for financial aid, scholarships, and to the college or university.

Subpart A. Ethical Practices

Minnesota State values the ethical treatment of students. Admissions staff should provide transparent information for informed decisions on college or university admissions. Admissions staff strive for accuracy in the application process.

Colleges and universities shall maintain and provide accurate, detailed, and comprehensive information on:

academic offerings including, but not limited to, academic programs, honors programs, and study-abroad programs, as applicable. This information must include any limitations for international students, and

on-campus housing availability, cost, and requirements at the time of the offer of admission and as applicable for the entire student life cycle.

Colleges and universities shall respond to students’ requests for additional substantive information related to enrollment or loan obligations in a timely manner.

Subpart B. Prohibited Behavior

Recruitment Tactics

Employees shall avoid high-pressure tactics, false claims, and taking advantage of students, and should refrain from repeated unsolicited contact. The college or university shall avoid aggressive or deceptive recruitment tactics (defined by federal regulations).

Colleges and universities shall not use high-pressure recruitment tactics such as engaging in same-day recruitment and registration for the purpose of securing current service member or veteran enrollments.

To foster collaboration, employees shall avoid spreading inaccurate or disparaging information about other schools, colleges, organizations, or professionals.

Colleges and universities shall not collect student contact information from deceptive websites promising job assistance or government benefits.

Colleges and universities shall not discourage students from seeking advice outside the college or university before making decisions or commitments.

Colleges and universities shall not induce or pressure a student to enroll by a specific deadline by offering scholarship monies, tuition discounting, fee waivers, financial aid, other assistance, or institution-branded gifts.

Application for Admission to the College or University

Employees shall not complete admission applications for students without student permission or apply the signature of a student to an application.

Colleges and universities shall not request candidates, counselors, or others to disclose or rank colleges and universities on any document.

Waitlists for admission to the College or University

Colleges and universities shall not require a deposit or set a fee for remaining on a waitlist.

Employee Compensation

Colleges and universities shall prohibit commission or incentive payments for securing enrollments in student recruiting or admission activities, except in the case of 3rd party recruitment of international students.

Part 5. Enrollment Agreements

Subpart A. Ethical Practices

Colleges and universities may require an enrollment agreement. If one is required, it should include only essential details like course of study, tuition, fees, and related information.

Students must have adequate time to review enrollment agreements and seek advice before signing without risking offers of admission and financial aid.

Subpart B. Prohibited Behavior

Enrollment agreements must not:

limit students’ complaint filing rights with accreditors or state agencies,

restrict students' ability to pursue legal action if dispute resolution processes fail to resolve the issue satisfactorily, and

limit students' ability to seek loan discharge under state or federal law.

If using an enrollment agreement, colleges and universities shall not require students to confirm enrollment until they have had time to apply for financial aid and review the (anticipated) financial aid award.

Part 6. Text Messaging

Subpart A. Ethical Practices

Colleges and universities may communicate with students via text messaging after a student provides their phone number to the college or university.

When students provide the college or university with their phone number, students opt-in to receiving official communication from the college or university.

Students may opt-out of receiving text messages. Colleges and universities shall respond to and monitor opt-out requests.

Subpart B. Prohibited Behavior
Colleges and universities shall not send text messages to students without receiving expressed consent (opt-in) from the student, unless related to the mission of the college or university or for emergency purposes.

Part 7. Financial Aid

Subpart A. Ethical Practices

Colleges and universities shall treat students ethically, respectfully, and professionally regarding financial aid decisions.

Only financial aid officers or their designated representatives shall address student inquiries regarding financial aid processes.

Colleges and universities must provide up-to-date information on costs, scholarships, and financial aid. Colleges and universities may do this through the use of an up-to-date net price calculator.

Following the timeframes established by the Federal Department of Education and the Minnesota State Office of Higher Education, colleges and universities shall ensure the student has had sufficient time to apply for financial aid. Colleges and universities accept applications for financial aid, regardless of whether or not the student has applied for admission or been accepted at the college or university.

If a student has applied for financial aid, colleges and universities shall provide sufficient time for them to understand the amount of federal and state financial aid they are eligible to receive. For additional information on this practice, see HLC Policy Recruiting, Admissions, and Related Enrollment Practices in the Related Documents section.

Subpart B. Prohibited Behavior

Employees shall not pressure students into making immediate financial aid decisions.

Colleges and universities are prohibited from providing incentives for securing federal financial aid decisions.

System Procedure History:

Date of Adoption: 10/13/25
Date of Implementation: 10/13/25
Date of Last Review:

Date & Subject of Amendments:

No Additional HISTORY.

System Procedure 1C.0.3 Ethical Practices in Recruitment of Students and Administration of Financial Aid

Related Documents:

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