Spanish AAN and Reg E Disclosures

Posted By: Tesla

Spanish AAN and Reg E Disclosures - 05/03/22 02:23 PM

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?
Posted By: rlcarey

Re: Spanish AAN and Reg E Disclosures - 05/03/22 02:28 PM

Any requirement to use them would be found in State law.
Posted By: Third Trip

Re: Spanish AAN and Reg E Disclosures - 05/03/22 03:43 PM

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.
Posted By: ccman

Re: Spanish AAN and Reg E Disclosures - 05/04/22 05:47 PM

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"!
Posted By: Tesla

Re: Spanish AAN and Reg E Disclosures - 05/04/22 05:51 PM

ccman - I thought the same thing about the FHFA information. Muy Bueno!