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Offering Loan Products In Spanish
by Andy Zavoina and Richard Insley, BOL Gurus
Question: Our bank is considering offering loan products in Spanish. Are there any particular compliance issues that would apply?
Answer by Richard Insley:
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Just be sure that English translations are readily available if a borrower requests disclosures in English (a non-Hispanic co-maker, for example.)
Answer by Andy Zavoina:
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I have always been hesitant to do this unless we knew we could service those the full needs of those customers for those products. That is, I didn't want to offer the disclosures for loans or deposits but be unable to answer question in that language if the customer couldn't speak English. I would see this as a possible bait and switch or deceptive practice. If you have the personnel to handle this task, you may meet some unmet needs.
But that is just a personal opinion.
Answer by Richard Insley:
BIO AND CONTACT INFO
You have very legitimate concerns, Andy. We ran into the same issues with braille and any other ADA-driven barrier-removal project. Before jumping into alternate forms of communication, banks should be sure they have the language skills to handle Spanish braille discussions, inquiries, and examinations.
First published on BankersOnline.com 08/4/03
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