Number: STU 130
Effective: July 1, 2021
Last Reviewed: November 16, 2021
Department: Admissions and One Stop
Last Revision: November 16, 2021


In accordance with federal regulations, 34 C.F.R. § 668.14.(b)(22), CWI will avoid unethical behavior when engaging in securing enrollments or awarding financial aid for current and prospective students.


Applies to any CWI employee, entity, or agent engaged in any student recruitment or admission activity, or in making decisions regarding the awarding of Title IV financial aid.


Service member — Someone who is a member of, applies to be a member of, performs, has performed, applies to perform, or has an obligation to perform, service in the uniformed services.

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

Securing enrollments or the awarding of financial aid – Activities that a person or entity engages in at any point in time through completion of an educational program for the purpose of the admission or matriculation of students for any period of time or the awarding of financial aid to students.

CWI employees will:

  • Refrain from providing any commission, bonus, or other incentives to any employee based directly or indirectly on securing enrollments or the awarding of financial aid.
  • Prohibit inducements of any kind other than salaries paid to employees, fees paid to contractors, or scholarships available, to any individual or entity for the purpose of securing enrollments of Service members and other students.

CWI employees will not:

  • Engage in high-pressure sales tactics with any prospective, applicant, or other students, including Service members, such as making multiple unsolicited contacts (3 or more), including contacts by phone, email, or in-person, and engaging in same-day recruitment and registration for the purpose of securing enrollments.
  • Receive compensation through commissions, bonuses, or other incentive payments, based on the number of students, including services members, referred, recruited, admitted, or enrolled. Offer or accept any reward or remuneration to influence an admission, scholarship, financial aid, or enrollment decision.
  • Accept any amount of cash, gift, or benefit in excess of a de minimus amount from any entity doing business with or seeking to do business with the institution, including service on advisory committees or boards beyond reimbursement for reasonable expenses directly associated with such service in relation to student recruitment services.