[jcomp55]

Good morning, is there any guidance you can refer me to in regards to LEP customers? My legal counsel has informed me that our bank does not have the capabilities needed to provide loan documents in languages other then English; therefor we are not able to create loans for non-English speaking customers as we can’t ensure they are understanding what they are signing. I’m searching for guidance to assist me in creating a script I can provide to our staff taking these phone calls, that ensures we are communicating this in a consistent and non-discriminatory manner. I found some information on the CFPB website, but most of what I’m finding does not address how to communicate when a bank doesn’t have the resources to assist the LEP customers. Are there any regulations or laws that address what a bank’s responsibilities are and are not in regards to this?
Thanks in advance for any assistance!

[jholzknecht]

Translated documents are one way to handle LEP customers. If your institution is not willing to spend the money to have translated documents, and many financial are in that situation, then consider another option, such as providing a translation service. In a translator service the documents are read to the LEP individual in the language of their choice. Such services are widely available.

A script that indicates a refusal to do business with LEP individuals might be construed as intentional national origin discrimination under the Equal Credit Opportunity Act and/or the Fair Housing Act.

[Author]

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