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#1255496 - 09/23/09 05:12 PM Borrowers don't speak English
Anonymous
Unregistered

We are a small town community bank. A relative of one of our existing customers has come to us to request a car loan. The problem is that the relative does not speak any English. We've never had to deal with this type of situation before. Our plan is to have our existing loan customer sign on the loan with her relative (and she will translate the information to her relative). Are there any problems with structuring the loan this way?

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#1255660 - 09/23/09 06:45 PM Re: Borrowers don't speak English Anonymous
YoungAndEager Offline
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Joined: Apr 2009
Posts: 135
Indiana
Do you have any employees speak this language that could sit down and translate the documents / disclosures? I was able to translate a overdraft repayment plan from English to Spanish in a day using an online translator. But, you have to have a good understanding of the language, because most translations require some tweaking.
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#1255700 - 09/23/09 07:08 PM Re: Borrowers don't speak English YoungAndEager
Rocky P Online
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Joined: Jun 2003
Posts: 7,650
Florida
IMHO, there may be some issues with the scenario.

What would be the need to have the existing customer sign on the loan with the relative? That could border on discrimination for national origin if the relative is otherwise qualified.

If the relative agrees, customer can be translator - if not, I would have a concern about privacy issues "forced" by the bank.

Also - if the loan goes past due, what is the bank going to say to the customer/how would they collect?
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#1256084 - 09/24/09 01:05 PM Re: Borrowers don't speak English Rocky P
YoungAndEager Offline
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Joined: Apr 2009
Posts: 135
Indiana
Souther Banker -- So are you suggesting they turn down the application based on the fact that this individual can not speak/read English?
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#1256128 - 09/24/09 01:49 PM Re: Borrowers don't speak English YoungAndEager
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:
That could border on discrimination for national origin if the relative is otherwise qualified.


If the relative does not have permanent residence status then there is no discrimination concern from Reg B's perspective. See the Commentary to 202.6(b)(7).
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The opinions expressed are mine and they are not to be taken as legal advice.

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