Number: FDCR.A.20.020

HLC is committed to promoting fundamental fairness and transparency in its institutions’ dealings as pertains to all aspects of the enrollment process. For purposes of this policy this includes lead generation, recruiting activities, admissions processing through matriculation, and related practices such as financial aid determinations and administration. This expectation applies comprehensively to prospective students and, to the extent applicable, current students (referred to collectively in this policy as students). In addition to requirements set forth in other HLC policies, HLC has established the following expectations for member institutions:

1. The institution treats students ethically, respectfully and professionally in the marketing, recruiting, admissions and financial aid process so that students can make informed enrollment decisions about matters such as enrollment and financial aid without being subjected to high-pressure tactics from the institution or a related contractor, including but not limited to:
   1. Falsely claiming that enrollment spots are limited or taking advantage of students’ lack of understanding to pressure students to enroll;
   2. Pressuring students to make an immediate financial aid decision;
   3. Engaging in repeated unsolicited contact.
2. All institutional recruiting, admissions and financial aid personnel have appropriate education, job titles, and skills for their role and are overseen by the institution, which enforces a formal code of conduct for all such personnel; the institution also oversees any third-party contractors who provide recruiting, admissions and financial aid services and assures that any personnel who work with their students have similar education, skills and experience as personnel employed by the institution. The institution ensures consistent, accurate information and a high quality of service is provided. As applicable, the institution exercises oversight that ensures adherence to any regulations or other requirements governing recruiting activities in particular areas, such as, for example, athletics.
3. The institution ensures that its recruiting, admissions and financial aid personnel accurately describe the nature of their role.
4. The institution makes its policies related to consumer protection accessible and transparent. Information provided to students during any aspect of the enrollment process is accurate, complete and up-to-date and is provided to all students without any requirement that such students provide their contact information.
5. The institution promptly honors any request from a student to remove that student’s name from phone, email or other contact lists. Student information collected through any aspect of the institution’s enrollment processes is maintained and protected as outlined in the institution’s data privacy policy, which must be prominently posted on the institution’s website.
6. The institution complies with HLC expectations related to the publication of student achievement data as outlined elsewhere in HLC policy.
7. Institutional recruiters, admissions officers, financial aid officers or appropriate third parties engaged in similar roles on the institution’s behalf may answer questions about the student application process for admissions and financial aid, but in no case will such personnel complete applications for students without student permission or apply the signature of a student to an application.
8. If an institution requires a student to sign an enrollment agreement, the enrollment agreement is limited to basic information about course of study, tuition and fees, and other related information. Any enrollment agreement shall not include language limiting a student’s ability to: (1) file a complaint with an accreditor or state agency; (2) take legal action in the event that any dispute resolution processes agreed to by the institution and the student are unsuccessful in resolving the dispute to the satisfaction of the parties; or (3) seek to discharge a student loan through remedies available to borrowers under state or federal law. Students are provided sufficient time, as determined by the situation and any mandates in state law, to review any enrollment agreement and to consult with others as a part of that review process before being required to sign the document or lose an offer of admission and related financial assistance.
9. Students have the right and responsibility to register for each academic term in which they are eligible to enroll. The institution does not automatically register any student in the next term without that student’s affirmative consent to such registration or the opportunity for the student to cancel that registration before the student is assessed tuition or fees for that term.
10. Prior to enrolling a student in a program or major, the institution ensures that the student has had sufficient time to review the institution’s policies and procedures; to understand the amount of federal, state and institutional financial aid the student is eligible to receive; to learn how many credits previously earned, if any, will transfer and whether those transferred credits will be applied to requirements of the major or general education or the process; and to understand the timeline for evaluation of those credits.
11. The institution shall not induce or pressure a student to enroll by a specific deadline outside of the regular process of scholarship monies, institutional discounting, fee waivers, financial aid, other assistance or institution-branded gifts of nominal value.
12. In addition to a policy related to return of Title IV funds, the institution has a refund policy to assure that students receive a refund where appropriate if they withdraw from an academic term or from an institution according to policies set forth by the institution.
13. The institution does not otherwise engage in aggressive or deceptive recruitment tactics or conduct, such as may be defined and prohibited by federal regulations. This prohibition includes, but is not limited to, the following institutional acts or omissions:
    1. Obtaining students’ contact information through websites that falsely claim to provide assistance with finding employment or obtaining government benefits;
    2. Discouraging students from consulting with parties unrelated to the institution prior to finalizing their decisions or commitments;
    3. Failing to timely respond to students’ requests for additional substantive information related to enrollment or loan obligations.
14. The institution shall not use threatening, abusive, or manipulative language to influence a student’s decision.

In addition, HLC may otherwise look into an allegation of a violation of this policy or any other HLC requirement designed to promote consumer protection during an evaluation visit, through its complaint process, or through any other appropriate mechanism. An institution that is found to have engaged in violations outlined in this policy shall be considered to be out of compliance with HLC requirements related to institutional integrity and may be found to be in violation of other HLC standards as well, and may be subject to HLC sanctions or withdrawal of accreditation as outlined in those policies.

Policy History

Last Revised: February 2023
First Adopted: November 2017
Revision History: Adopted November 2017, effective September 2019; revised February 2022, February 2023
Notes: In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.” Policy renumbered in February 2023 (former policy number CRRT.C.10.010).