| Course | GB590 Ethics in Business and Society |
|---|---|
| Unit | Unit 9 |
| Paper type | Ethics program recommendation |
| Length | About 900 words, 6 pages double-spaced |
| Format | APA 7 student paper |
| School | Purdue University Global |
| Program | MBA |
| Updated | October 2026 |
Free sample paper for GB590 Unit 9
Seven Minutes a Call: A Unit 9 Ethics Program Recommendation for a Student Loan Servicer
[Student Name]
Purdue University Global
GB590: Ethics in Business and Society
Unit 9 Ethics Program Recommendation
[Instructor Name]
[Date]
The servicer, its staff and every figure are composite and illustrative; the enforcement history, frameworks and sources cited are real.
Summary
TO: Chief executive and board risk committee FROM: Ethics and compliance office SUBJECT: Recommendations to rebuild the ethics program around agent incentives
The servicer's code of conduct prohibits steering borrowers, yet an internal audit found that agents placed distressed borrowers in repeated forbearances far more often than they enrolled them in income-driven plans, which usually serve such borrowers better. The cause is not a lack of rules but a measurement system that rewards short calls. Six recommendations follow, each with an owner, an estimated cost and a measure. Together they would add about $7.4 million a year in agent time, a cost that is small against the regulatory and contract risk the current pattern creates.
Diagnosis
The servicer manages federal and private student loans for about 3.2 million borrowers and employs about 1,900 call center agents. Agents are evaluated on average handle time, with a target of seven minutes, and on calls answered per hour, and these measures drive about 30 percent of their quarterly bonus.
The audit. A review of 4,000 recorded calls from distressed borrowers, those reporting job loss or inability to pay, found that 71 percent were placed in forbearance and only 14 percent were told about income-driven repayment, under which payments are set as a share of income and can fall to zero. Forbearance pauses payments but lets interest accrue, and borrowers placed in repeated forbearances often owe more when it ends.
The survey. In an anonymous survey, 47 percent of agents agreed that they would be penalized for spending extra time explaining repayment options, and 38 percent said they had been told by a supervisor to keep distressed calls short.
The history. The Consumer Financial Protection Bureau sued another large servicer in 2017, alleging it steered borrowers into forbearance instead of income-driven plans, and in 2024 that servicer agreed to pay $120 million and to stop servicing federal student loans (Consumer Financial Protection Bureau, 2024). The servicer's own federal contracts include performance and conduct requirements under which a similar finding could cost it accounts.
The code told agents not to steer borrowers; the bonus told them every extra minute would cost them money.
Why More Rules Would Not Help
The servicer's existing response has been to add training modules and reminders about the code. Paine (1994) distinguished a compliance approach, which relies on rules, monitoring and penalties to prevent misconduct, from an integrity strategy, which aligns the organization's systems, including pay and performance measures, with the values it states. The steering pattern is a textbook case of a compliance approach failing: the rule against steering exists, agents know it, and the measurement system works against it. Employee surveys across several large firms found that programs grounded in shared values, fair treatment and steady attention from leaders cut unethical conduct more than formal compliance activity on its own (Treviño et al., 1999). Adding more rules to a system that pays for the opposite would make the code look more hollow, not less.
Six Recommendations
1. Replace handle time with resolution quality. Remove average handle time from the bonus for distressed-borrower calls and measure instead whether the agent screened the borrower for income-driven eligibility. Owner: vice president of operations. Cost: included in recommendation 6. Measure: share of distressed borrowers offered an income-driven plan, target 90 percent.
2. Pay for the right outcome. Redirect the 30 percent of bonus now tied to speed toward call quality scores and completed income-driven enrollments. Owner: chief human resources officer. Cost: neutral. Measure: enrollments per distressed call.
3. Change the order of options. Require agents to present income-driven repayment before forbearance on every distressed call, with forbearance offered only when the borrower is ineligible or prefers it after hearing the options. Owner: compliance. Cost: minimal. Measure: audit compliance, target 95 percent.
4. Move quality review out of operations. Create a call review team reporting to compliance that samples 2 percent of distressed calls each month. Owner: chief compliance officer. Cost: about $900,000 a year for twelve reviewers. Measure: monthly steering rate.
5. Open a channel outside the supervisor chain. Establish a hotline and an ombudsperson for agents to report pressure to shorten calls, with a written non-retaliation policy. Owner: general counsel. Cost: about $250,000 a year. Measure: reports received and resolved.
6. Staff for longer calls. Distressed calls are about 18 percent of volume; handling them properly would add roughly 140 agents. Owner: vice president of operations. Cost: about $6.2 million a year. Measure: service levels on all calls held at current targets.
Making the Case to the Board
Taken together, the six changes would add roughly $7.4 million to annual operating cost. The servicer's federal and private contracts produce about $410 million in annual revenue, and a single enforcement action of the kind brought against its competitor could cost far more than a decade of these changes, before counting lost contracts. The changes would also reduce borrower complaints, which the federal contracts track. The board's risk committee should approve them as a risk control, and should receive the steering rate as a standing measure.
References
Consumer Financial Protection Bureau. (2024, September 12). CFPB bans Navient from federal student loan servicing and orders the company to pay $120 million for wide-ranging student lending failures [Press release].
Paine, L. S. (1994). Managing for organizational integrity. Harvard Business Review, 72(2), 106-117.
Treviño, L. K., Weaver, G. R., Gibson, D. G., & Toffler, B. L. (1999). Managing ethics and legal compliance: What works and what hurts. California Management Review, 41(2), 131-151. https://doi.org/10.2307/41165990
Reading the GB 590 Unit 9 instructions
The ninth GB590 assignment asks you to recommend an ethics program or culture change for an organization with a specific problem. Begin with a short summary of your recommendations for a senior reader. Diagnose the problem with evidence, such as audits, surveys or incidents, and identify its root cause rather than its symptoms. Explain, using course frameworks, why the organization's current approach has not worked. Then present a set of recommendations, naming for every one the person responsible, the expected cost and the measure that shows it worked. Address incentives and reporting channels as well as rules and training. Close by making the case to the people who must approve and fund the program. Six to seven pages in memo form with APA 7 citations is common.
How the GB 590 Unit 9 example is put together
The memo opens with a summary addressed to the chief executive and the board risk committee. The diagnosis draws on an audit of 4,000 recorded calls, an anonymous agent survey and the CFPB's 2024 action against another servicer, and the highlighted line contrasts the code with the bonus. A section uses Paine's distinction between compliance and integrity strategies, and survey evidence from Treviño and colleagues, to explain why added training has not worked. Six recommendations follow, from removing handle time on distressed calls to adding 140 agents, every one assigned to a named executive with a price and a target. The closing section sets $7.4 million a year against $410 million of contract revenue and enforcement risk.
Where the points sit in the GB590 Unit 9 rubric
In this GB590 ethics program memo, the most points go to a diagnosis that finds the root cause. Audit samples, survey results or documented incidents prove to the instructor that the misconduct is measurable and widespread. Explaining why existing rules or training have not worked, with a course framework, demonstrates conceptual understanding. Each recommendation should name who carries it out, its expected price and the number that will show progress, because that is what makes a program manageable. Attention to incentives and reporting channels, not only rules, shows the writer understands how culture forms. Making the case to approvers in their own terms, risk and revenue, shows practical judgment. Memo format, a concise summary and APA 7 citations complete the grade.
Common GB590 Unit 9 mistakes, and how to avoid them
GB590 ethics program papers often recommend more training and a stronger code when the problem is an incentive that pays for the opposite. Others diagnose by assertion, without evidence that the misconduct is widespread or what causes it. Recommendations frequently lack owners, costs or measures, so no one could implement them. A common gap is ignoring reporting channels, which matter most when the pressure comes from supervisors. Writers also forget the audience: a board approves programs on risk and cost, not on principle alone. Find the root cause with evidence, explain why current rules fail, assign every recommendation a responsible person, a price and a measure, open channels outside the chain of pressure and make the case in the approvers' terms. Send your case for a free custom ethics program memo.
Get a GB590 Unit 9 example written to your instructions
Send the company profile or case your Unit 9 prompt supplies, any program elements it requires and the rubric. A memo comes back within 24-48h, recommendations first, each tied to a diagnosed weakness and carrying an owner, a cost and a measure, with the framework your readings name applied rather than cited. First requests cost nothing; the hotel operator is imaginary. The paper above is an original model document written by our desk, not a submitted student paper and not an official Purdue University Global document.
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GB590 Unit 9 questions, answered
What is the difference between a compliance program and an integrity strategy?
In Lynn Sharp Paine's account, a compliance approach centers on rules, monitoring and penalties designed to prevent misconduct, while an integrity strategy builds shared values and managerial responsibility so employees act well without being watched. The GB590 example uses that contrast to explain why this company's failure, employees who doubt they will be heard, needs more than stricter rules.
Where can I find a free GB590 Unit 9 sample paper?
This page holds a full GB590 Unit 9 ethics program recommendation for a composite student loan servicer, with an evidence-based diagnosis, six recommendations with owners, costs and measures, and a board case.
Why would more training not fix the steering problem?
Agents already knew the rule against steering. The bonus rewarded short calls, so training would ask them to act against their pay. Changing the measure removes the conflict that training cannot.
What is income-driven repayment?
A federal student loan plan that sets payments as a share of the borrower's income, sometimes as low as zero. It usually serves distressed borrowers better than repeated forbearance, during which interest keeps accruing.
What does the ombudsperson add to the hotline?
A hotline takes reports; an ombudsperson can investigate pressure from supervisors confidentially and raise patterns with senior leaders. Agents told to keep calls short by their own supervisor need a route that bypasses that supervisor.