The Consumer Finance Protection Bureau (“CFPB”) recently published Spanish translations of Regulation B sample forms. The publications state that the translations are not part of Appendix C to Regulation B and do not qualify for safe harbor protections under section 706(e) of the Equal Credit Opportunity Act (“ECOA”). The CFPB encourages lenders to “ascertain the language preference of their borrowers and where appropriate provide the translated materials” which have been issued as compliance aids.
The introduction for each sample form references the CFPB’s statement from January 13, 2021, which provided guidance and encouraged financial institutions to offer products and services to limited English proficiency (LEP) consumers.
Spanish translations are available for the following sample forms:
C-1: Notice of Action Taken and Statement of Reasons – Adverse Action based on outside source other than CRA
C-2: Notice of Action Taken and Statement of Reasons
C-3: Notice of Action Taken – Credit Score
C-4: Notice of Action Taken – Counteroffer
C-5: Disclosure of Right to Request Specific Reason for Credit Denial
C-6: Notice of Incomplete Application
C-7: Notice of Action Taken – Business Credit
C-8: Disclosure of Right to Request Specific Reason for Credit Denial – Business Credit
As there is no requirement to use the Spanish translations, DocMagic will make the optional disclosures available by request beginning on July 14, 2022. As these are indicated as compliance aids and do not provide a safe harbor under Regulation B, these forms should be provided in addition to the standard disclosures. For any additional questions or for assistance, please contact DocMagic’s Customer Service.
