Letter from consumer, civil rights and banking organizations supporting the Bureau’s efforts to provide LEP borrowers with access to language assistance and expressing concern regarding one aspect of the proposal. “We believe there are meaningful and operationally feasible approaches that can be pursued to improve language access for borrowers, which we will detail in our individual comment letters.
“While we support the Bureau’s efforts to provide language access in the mortgage market, we write to you jointly to express our shared concerns regarding the marketing-related component of the Bureau’s proposed LEP requirements, in which, upon borrower request, a servicer must provide translation or interpretation services for any language the servicer knows or should have known was used in marketing to the borrower. We believe that this particular standard is too broad and operationally cumbersome for servicers to execute; as a result, it has the potential to constrain, rather than expand, language access.”
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