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#2269969 - 05/03/22 02:23 PM Spanish AAN and Reg E Disclosures
Tesla Offline
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Joined: Nov 2003
Posts: 3,694
I apologize in advance if someone asked this already but I did a search for "Spanish" and nothing came up. For the recently released Spanish language documents, I did not see a requirement to use them. Did I miss something? How are others implementing this, if they are?
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General Discussion
#2269970 - 05/03/22 02:28 PM Re: Spanish AAN and Reg E Disclosures Tesla
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
Any requirement to use them would be found in State law.
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#2269978 - 05/03/22 03:43 PM Re: Spanish AAN and Reg E Disclosures Tesla
Third Trip Offline
Junior Member
Joined: Jul 2016
Posts: 25
When TRID was instituted, Spanish-language disclosures were also released at that time, so it looks like this latest release is a continuation of the movement to provide options for customers who are not English-proficient.

Like rlcarey said, there may be only State law requirements. However, the new UDAAP guidelines from the CFPB, and their emphasis on discrimination in the provision of financial services should encourage banks to do a deep dive on their demographics, and the makeup of their assessment areas to determine if providing disclosures only in English hinders consumer acquisition and management of financial services.

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#2270040 - 05/04/22 05:47 PM Re: Spanish AAN and Reg E Disclosures Third Trip
ccman Offline
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Joined: Sep 2007
Posts: 924
The question before us, is this a requirement of federal regs or not?

At present, we do not have a need to provide to our customers as the vast majority are English speaking.

What a coincident that the FHFA revives their push to collect this info at the same time the bureau introduces
Spanish language disclosures! "Muy Bueno"!

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#2270041 - 05/04/22 05:51 PM Re: Spanish AAN and Reg E Disclosures Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,694
ccman - I thought the same thing about the FHFA information. Muy Bueno!
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