November 2017

Spotlight on serving 

limited English proficient 

consumers 

Language access in the consumer financial marketplace
1 CONSUMER FINANCIAL PROTECTION BUREAU

CFPB research, tools, and resources for financial educators 

An essential part of the mission of the Consumer Financial Protection Bureau (CFPB) is to 

empower consumers to take more control over their financial lives. Since the CFPB opened its 

doors in 2011, it has worked to improve the financial literacy of consumers in the United States 

and to ensure access to tools, information, and opportunities for skill-building that can support 

consumers in managing their finances and working to achieve their own life goals. 

The CFPB’s principal financial education mandate is set forth in the Dodd-Frank Wall Street 

Reform and Consumer Protection Act (Dodd-Frank Act). The Dodd-Frank Act created the CFPB

and mandated the establishment of an Office of Financial Education to “be responsible for 

developing and implementing initiatives intended to educate and empower consumers to make 

better informed financial decisions.”1

To better help consumers make well-informed financial decisions and achieve their own life 

goals, the CFPB has sought to increase understanding of effective practices in financial 

education.

The CFPB conducts this research to inform the CFPB's own financial education efforts and to 

amplify the work of others who have a common interest in improving the financial well-being of 

consumers. 

The CFPB's goal for its financial education activities is to help consumers move toward financial 

well-being. In the CFPB’s definition of financial well-being, consumers: 

 have control over day-to-day, month-to-month finances;

 have the capability to absorb a financial shock;

 are on track to meet financial goals; and

 

1 See 12 U.S.C. § 5493(d)(1).
2 CONSUMER FINANCIAL PROTECTION BUREAU

 have the financial freedom to make choices that allow them to enjoy life.

To learn more, visit the CFPB Resources for Financial Educators webpage at

consumerfinance.gov/adult-financial-education.

To contact the CFPB regarding this report or financial education in general, send an email to 

financialeducation@cfpb.gov. 
3 CONSUMER FINANCIAL PROTECTION BUREAU

Table of contents

Table of contents.........................................................................................................3

1. Introduction and executive summary .................................................................5

1.1 Background ............................................................................................... 5

1.2 Report content .......................................................................................... 7

2. Background.........................................................................................................10

2.1 Language needs....................................................................................... 10

2.2 Challenges associated with limited English proficiency ........................ 12

3. Industry interviews: Common themes..............................................................17

3.1 Assessment of language needs................................................................ 18

3.2 Centralized point of contact for technical assistance............................. 18

3.3 Translation and interpretation systems ................................................. 19

3.4 Training and support for staff and contractors...................................... 21

3.5 Interactions with consumers ..................................................................22

4. Conclusion ..........................................................................................................24

Appendix A: LEP Resources................................................................................25

Federal interagency LEP website .................................................................... 25

Bilingual glossaries..........................................................................................26

Forms and disclosures.....................................................................................26
4 CONSUMER FINANCIAL PROTECTION BUREAU

Financial education resources.........................................................................28
5 CONSUMER FINANCIAL PROTECTION BUREAU

1. Introduction and executive 

summary

1.1 Background

The CFPB works to ensure a fair, transparent, and reliable consumer financial marketplace. A 

well-functioning marketplace includes financially capable consumers. Financial education can 

help consumers make the most of their circumstances and what the consumer financial 

marketplace has to offer. However, consumers who are Limited English Proficient2 (LEP) often 

encounter significant barriers to participating in the consumer financial marketplace, including

completing key financial documents, managing bank accounts, resolving problems with 

financial products, and accessing financial education. Further, a lack of English-language skills 

can hinder their financial literacy, making it difficult to conduct everyday financial affairs.3

 

2 As used in this document, LEP means individuals who do not speak English as their primary language and who have 

a limited ability to speak, write, read, or understand English.

3 U.S. Government Accountability Office, GAO-10-518, Consumer Finance: Factors Affecting the Financial Literacy 

of Individuals with Limited English Proficiency (May 2010), available at http://www.gao.gov/products/GAO-10-

518.
6 CONSUMER FINANCIAL PROTECTION BUREAU

As consumers navigate their financial lives, they face many choices and decisions. A principle of

effective financial education is the creation of an environment that empowers consumers to take 

actions that support their financial goals.4 This principle can be applied to the creation of a wellfunctioning financial marketplace that is accessible to all consumers regardless of their primary 

language.

Financial institutions can play an important role in creating an inclusive environment in the 

financial marketplace. They are uniquely positioned to support access to financial products and 

services because of the various touch points they have with consumers, including those with 

limited English proficiency. Financial transactions can present an opportunity for consumers to 

build their financial capability and participate in the financial system. Building education into 

the offering and use of financial products can be an effective strategy for facilitating positive 

financial outcomes for consumers.5 Moreover, the effective integration of LEP consumers into 

the financial marketplace has the potential to create positive benefits for consumers and the 

financial services industry alike.

 

4 The CFPB released a report in June 2017 entitled Effective financial education: Five principles and how to use them

(2017), available at consumerfinance.gov/data-research/research-reports/effective-financial-education-fiveprinciples-and-how-use-them/. The five principles build on insights marshalled from many fields of study about 

how people make financial decisions, and on what the CFPB has learned about consumers’ experiences in the 

financial marketplace. The Principles are compiled from research on what drives people to take actions aimed at 

improving their money situation. The five principles are: (1) know the individuals and families receiving services; 

(2) provide actionable, relevant, and timely information; (3) improve key financial skills; (4) build on motivation; 

and (5) make it easy to make good decisions and follow through. 

5 Journal of Financial Counseling and Planning, Saving for Success: Financial Education and Savings Goal 

Achievement in Individual Development Accounts (January 2011), available at

http://files.eric.ed.gov/fulltext/EJ952959.pdf. 
7 CONSUMER FINANCIAL PROTECTION BUREAU

1.2 Report content

This report presents information that the CFPB learned in interviews with a broad spectrum of 

stakeholders, including representatives from financial institutions of various sizes, trade 

associations, other federal agencies, and non-profit consumer advocacy groups. In addition, this

report includes secondary research on current practices for serving LEP individuals in the 

financial services industry and on the experience of consumers as reflected through the CFPB’s

complaint system. 

It is important to note that the practices described in this report are not exhaustive and that 

this document is not intended to interpret federal consumer financial law or any other statute 

or rule and should not be construed as a mandate, guidance, or a requirement. The purpose of 

this report is to share general consumer information and raise awareness about the issues that 

LEP consumers face when participating in the consumer financial marketplace. It is not 

intended to provide legal advice or regulatory guidance or serve as a substitute for financial 

institutions’ own legal counsel.

1.2.1 Insights from financial institutions

The CFPB identified several common themes in its interviews with representatives from several 

financial institutions. The themes are outlined below and further detailed in Section 3.

 Assessment of language needs. Many institutions review demographic data about

the localities they serve from sources such as the U.S. Census Bureau to determine their 

potential customers’ likely language preferences. Some institutions with a national 

footprint largely focus their resources on building out capabilities to serve Spanishspeaking consumers, while regional institutions typically align any language-focused 

resources with local demographics.

 Centralized point of contact for technical assistance. Many larger institutions 

that provide some language services have a central point of contact that provides internal

technical assistance to the institution’s employees on any language-related initiative.

Depending on the institution, some functions of the central point of contact may include: 

annually reviewing processes and procedures for using non-English languages;

evaluating which areas of business would most benefit from LEP services; developing 

quality control mechanisms; and establishing translation and interpretation policies.
8 CONSUMER FINANCIAL PROTECTION BUREAU

 Translation and interpretation systems. Most of the larger institutions that 

provide language services reported having systems for translation (written) and 

interpretation (oral) to help ensure consistency and accuracy.6 Many institutions 

translate for meaning (rather than word-for-word), use back-translation (which involves 

taking a translated document and having another party translate it back to English) to 

validate third-party translations, and use internal or external bilingual glossaries. Some 

institutions leverage various technological solutions, including those from third-party 

vendors, to assist with translations and interpretations.

 Training and support for staff and contractors. Institutions that provide 

language services use various methods to ensure that staff and contractors have the 

necessary language and cultural competencies to serve LEP consumers. Some 

institutions hire employees with foreign language fluency, cultural competency, or

financial expertise. These institutions often require either an internal or external 

certification for written and verbal competency. Institutions that rely primarily on thirdparty translators or interpreters often retain some language experts on staff for quality 

control purposes.

 Interactions with consumers. Institutions that provide language services shared a 

range of approaches to interact with LEP consumers in their preferred language in 

different settings. Many institutions provide verbal interpretations via phone and offer 

multiple language settings on their digital services and access points. Most of the 

institutions reported that their written contracts or agreements were available only in 

English.

 

6 This paper follows the convention of translation referring to written language and interpretation referring to spoken 

language.
9 CONSUMER FINANCIAL PROTECTION BUREAU

1.2.2 Additional insights

The CFPB identified additional insights from trade associations, federal agencies, and non-profit 

consumer advocacy groups. These insights are outlined below.

 There is a general understanding that language cannot always be separated from culture,

and that offering information in languages other than English does not necessarily mean 

that all LEP populations will be able to access, understand, or use the information 

provided. 

 In some cases the challenge is not translating materials, but rather ensuring that 

materials are written at a reading level that is accessible to the average U.S. adult

regardless of the language used.

 In many families, children play a role in helping LEP relatives understand legal terms 

and other highly-specialized terminology, which the children may or may not translate or 

interpret accurately or fully understand themselves.

 There are no nationally-recognized organizations that offer financial interpreter and 

translator certification. 

 In general, the number of certified financial interpreters and translators is low and the

availability of translation services with the capacity to handle high volumes of translation 

work is limited, particularly for languages other than Spanish. 

 Using a glossary of terms is helpful to maintain consistency. However, not all financial 

institutions or other entities use glossaries, and those that use glossaries vary in the 

translations used. The inconsistency of the translation of terms across the financial 

services industry and other entities can sometimes cause confusion for consumers.

 To communicate the intended meaning, successful translation and interpretation of 

financial terms requires language fluency, cultural competency, and financial expertise.

For example, technical terms in the U.S. financial system such as “overdraft protection,” 

“balloon payment,” “401(k)” – may not have equivalent terms in some languages. Even if 

equivalent terms exist, translations may create more confusion than clarity. 
10 CONSUMER FINANCIAL PROTECTION BUREAU

2. Background

2.1 Language needs

Over 65 million people, or about 21 percent of the U.S. population over the age of five, speak a 

language other than English at home.7 Of these, two-fifths have limited proficiency in English. 

Spanish is the most common non-English language spoken at home, with approximately 40 

million speakers in the U.S.8 Spanish speakers also comprise the largest share of the LEP 

population, followed by Chinese, Vietnamese, Korean, and Tagalog speakers. The number and 

share of LEP speakers of each of these languages is shown in Table 1. These five languages are 

spoken by more than 78 percent of LEP individuals. While LEP individuals tend to be 

concentrated in the states with the largest populations, several smaller states including New 

Jersey, Hawaii, and Nevada have relatively high proportions of residents with limited English 

 

7 U.S. Census Bureau, 2016 American Community Survey 1-Year Estimates , Table B16001: Language Spoken at 

Home by Ability to Speak English for the Population 5 Years and Over (2016), available at

https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk.

8 Ibid.
11 CONSUMER FINANCIAL PROTECTION BUREAU

proficiency.9 Overall, LEP residents in California, Texas, and New York account for nearly 50 

percent of the total LEP population in the United States.

The LEP population overlaps significantly with the immigrant population in the United States.

The U.S. Census Bureau collects data on the English-speaking ability of the U.S. foreign-born 

population, which they define as anyone who is not a U.S. citizen or national at birth.10 Of the 

approximately 43 million foreign-born individuals over the age of five living in the U.S., about 

half have limited English proficiency.11 Moreover, foreign-born individuals comprise more than 

80 percent of the LEP population in the United States.

 

9 U.S. Census Bureau, 2016 American Community Survey 1-Year Estimates, Table B06007: Place of Birth by 

Language Spoken at Home and Ability to Speak English in the United States (2016), available at

https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_16_1YR_B06007&prodT

ype=table.

10 U.S. Census Bureau, 2015 Subject Definitions (2015), available at https://www.census.gov/programssurveys/acs/technical-documentation/code-lists.html. 

11 U.S. Census Bureau, 2016 American Community Survey 1-Year Estimates , Table B16005: Nativity by Language 

Spoken at Home by Ability to Speak English for the Population 5 Years and Older (2016), available at

https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_16_1YR_B16005&prodT

ype=table.
12 CONSUMER FINANCIAL PROTECTION BUREAU

TABLE 1: TOP FIVE MOST COMMONLY SPOKEN LANGUAGES BY LEP INDIVIDUALS IN THE U.S.12

Language Speaker 

population*

LEP 

population

Percent of speaker 

population

Percent of total 

LEP population

Spanish 40,489,813 16,590,392 41.0% 63.6%

Chinese 3,372,930 1,854,311 55.0% 7.1%

Vietnamese 1,509,993 875,720 58.0% 3.4%

Korean 1,088,788 583,054 53.6% 2.2%

Tagalog 1,701,960 542,749 31.9% 2.1%

*Number of people who reported speaking a language other than English at home.

2.2 Challenges associated with limited 

English proficiency

LEP consumers often face numerous obstacles to accessing financial products and services. 

Many of these challenges stem from language access issues. Financial disclosures and written 

documents are generally not available in LEP consumers’ preferred languages, and some

financial institutions do not have bilingual employees or access to interpretation services.

2.2.1 Language access

Consumers with limited English proficiency face language-based barriers across the financial 

services industry. The Federal Deposit Insurance Corporation’s (FDIC) biennial survey on 

 

12 U.S. Census Bureau, 2016 American Community Survey 1-Year Estimates , Table B16001: Language Spoken at 

Home by Ability to Speak English for the Population 5 Years and Over (2016), available at

https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk.
13 CONSUMER FINANCIAL PROTECTION BUREAU

unbanked and underbanked households indicated that households that spoke only Spanish were 

unbanked (defined as lacking a checking or savings account) at five times the rate of households 

where Spanish was not the only language spoken.13 In particular, the 2015 survey found that 31 

percent of households that spoke only Spanish were unbanked compared to 6.5 percent of 

households where Spanish was not the only language spoken. Nearly a third of households that

only spoke Spanish were underbanked (defined as having an account at an insured institution 

but also obtaining financial services and products outside the banking system), compared to 

one-fifth of households where Spanish was not the only language spoken. The share of 

households that only spoke Spanish that were underbanked in the 2015 survey increased 

significantly from the share in the 2013 survey, from 23.7 percent to 29.1 percent.14 These results 

show that many Spanish-speaking LEP households continue to face persistent barriers to 

accessing mainstream financial products.

The CFPB’s research on the financial education needs of immigrants, including those with 

limited English proficiency, further demonstrates the language access issues in the financial 

marketplace.15 The CFPB identified the ubiquity of technical terms unique to the U.S. financial 

system as a key challenge for immigrants. Inconsistency in the translations of such terms was 

also identified as an issue. Technical terms may not have equivalent terms in some languages, 

and even if equivalent terms exist, translations may create more confusion than clarity. As a 

result, successful translation and interpretation of financial terms requires language fluency, 

cultural competency, and financial expertise.

 

13 Federal Deposit Insurance Corporation, 2015 FDIC National Survey of Unbanked and Underbanked Households

(2016), available at https://www.fdic.gov/householdsurvey/.

14 The report noted that the increase in the underbanked share of households that spoke only Spanish between 2013 

and 2015 was statistically significant at the 10 percent confidence level.

15 CFPB, Financial education programs serving immigrant populations (2016), available at

consumerfinance.gov/about-us/blog/immigrants-facing-unique-financial-challenges/.
14 CONSUMER FINANCIAL PROTECTION BUREAU

The CFPB’s report on the financial education needs of immigrants also identified that children 

often play a role in helping LEP relatives understand legal terms and other highly-specialized 

terminology.16 However, children might not translate or interpret accurately, or fully understand

the complex financial or legal concepts themselves.

In addition to the research reviewed above, the CFPB accepts consumer complaints about 

financial products and services and has received complaints from consumers that express 

common themes associated with limited English proficiency. In many of these complaints, 

consumers described a lack of translated material. Others noted a lack of interpretation services. 

Complaints about translation and interpretation services also tended to describe confusion and 

misunderstanding. In many complaints, consumers reported that they did not understand the 

terms of a financial product or service due to a language barrier. These observations illustrate 

the challenges that some consumers face when attempting to participate in the consumer 

financial marketplace.

2.2.2 Financial literacy

In addition to language access issues, LEP consumers frequently face unique barriers to

strengthening their financial capability. The Government Accountability Office (GAO) studied 

the extent to which limited English proficiency creates barriers to developing the knowledge and 

skills necessary for effective money management in the U.S. financial system.17 The GAO 

interviewed staff at financial institutions, federal agencies, and community and advocacy 

organizations that work with LEP individuals. It found that limited proficiency in English 

hindered LEP consumers’ ability to communicate with English-speaking staff, initiate financial 

transactions, and access financial tools and educational materials. The GAO has specifically 

reported that LEP individuals have difficulty completing key financial documents such as

 

16 GAO 2010.

17 Ibid.
15 CONSUMER FINANCIAL PROTECTION BUREAU

applications and contracts; managing bank accounts, including writing checks and tracking 

withdrawals and deposits; asking questions about and resolving problems with financial 

products and services; and accessing financial education materials.

The GAO also found that having limited English proficiency exacerbates the challenges that

many consumers, including proficient English speakers, confront with complex financial 

products. Citing two of its previous reports, the GAO in 2010 noted that credit card disclosures 

were often written above the eighth-grade reading level, which, at that time, the GAO identified

as the average reading level of about half the U.S. adult population.18 Similarly, the GAO 

identified eleventh-grade reading level as the average difficulty of disclosures for alternative 

mortgage products.19 Focus groups conducted by the GAO20 and a report by Lutheran 

Immigration and Refugee Service21 indicated it can take up to five years of regular 

communication and practice in English for an individual who lacks English proficiency to 

acquire the advanced literacy skills necessary to understand complex written communication.

The relationship between English proficiency and financial literacy is especially apparent in the 

mortgage market. According to focus groups conducted on behalf of Freddie Mac and Fannie 

Mae, Spanish-speaking and Vietnamese-speaking LEP mortgage borrowers often do not 

 

18 Ibid.

19 U.S. Government Accountability Office, GAO-06-1021, Impact on Defaults Remains Unclear, but Disclosure of 

Risks to Borrowers Could Be Improved (September 2006), available at http://www.gao.gov/products/GAO-06-

1021.

20 GAO 2010.

21 Lutheran Immigration and Refugee Service, Financial Literacy for Newcomers: Weaving Immigrant Needs into 

Financial Education (2006), available at www.higheradvantage.org/wpcontent/uploads/2012/05/rw_financial_literacy.pdf.
16 CONSUMER FINANCIAL PROTECTION BUREAU

understand English documents and often misinterpreted the English documents.22 A report by 

the California Reinvestment Coalition that analyzed Home Affordable Modification Program 

(HAMP) data and survey data from housing counselors also found that LEP borrowers had an 

especially difficult time navigating the complex mortgage loss mitigation process.23

 

22 Freddie Mac and Fannie Mae, Language Access for Limited English Proficiency Borrowers: Final Report (2017), 

available at https://www.fhfa.gov/PolicyProgramsResearch/Policy/Documents/Borrower-Language-Access-FinalReport-June-2017.pdf.

23 California Reinvestment Coalition and Urban Strategies Council, Race to the Bottom: An Analysis of HAMP Loan 

Modification Outcomes by Race and Ethnicity for California (2011), available at

http://www.calreinvest.org/news/race-to-the-bottom-an-analysis-of-hamp-loan-modification-outcomes-by-raceand-ethnicity-for-california.
17 CONSUMER FINANCIAL PROTECTION BUREAU

3. Industry interviews:

Common themes

While LEP communities often face challenges in the marketplace, there are many financial 

service industry entities that serve them.

To prepare this report, the CFPB conducted unstructured interviews with representatives from a 

number of financial institutions of various sizes and trade associations in April 2017. The CFPB

then summarized what it heard from these entities about how they interact with LEP 

consumers. The practices described below were drawn from these conversations and the CFPB’s 

broader understanding of the market. The list of practices is not intended to be comprehensive 

or representative of industry practices as a whole.

While the CFPB believes that gathering and sharing information about providing financial 

products and services to LEP consumers is important, the practices described in this document 

are for informational purposes and do not constitute an endorsement of specific practices by the 

CFPB. Moreover, we recognize that language services may not be available in many 

circumstances. Whether a financial institution decides to provide services in languages other 

than English and the extent of those services throughout the product lifecycle may depend on 

many considerations, including the institution’s particular circumstances.

It is important to note that the practices described in this report are not exhaustive and that 

this document is not intended to interpret federal consumer financial law or any other statute 

or rule and should not be construed as a mandate, guidance, or a requirement. The purpose of 

this report is to share general consumer information and raise awareness about the issues that 

LEP consumers face when participating in the consumer financial marketplace. It is not 

intended to provide legal advice or regulatory guidance or serve as a substitute for financial 

institutions’ own legal counsel.
18 CONSUMER FINANCIAL PROTECTION BUREAU

3.1 Assessment of language needs

Many institutions review demographic data from the U.S. Census Bureau on the localities they 

serve to determine their potential customers’ likely language preferences. Some institutions 

request their customers’ language preferences to inform communications with customers. In 

fact, the Federal Housing Finance Agency recently announced the addition of a language 

preference question to the Uniform Residential Loan Application (URLA), to assist lenders in 

identifying the language preference of mortgage applicants who choose to provide that 

information.

Institutions with a national footprint largely focus their language access resources on building 

out their capacity to serve Spanish-speaking consumers, including hiring bilingual agents and 

providing in-language servicing for particular product lines. Many cited national demographics 

as the reason for this choice. These institutions generally provide some services in languages

other than English or Spanish through third-party language line interpreters. To align any 

language-focused resources with local demographics, some institutions with a regional focus 

provide certain support in Spanish, Chinese, and several other languages. 

Those institutions with whom the CFPB spoke also noted that they pay close attention to the 

demographics and language preferences around current and planned branch locations. For 

example, some institutions hire branch personnel with specific language and cultural 

competencies.

Some institutions specifically highlighted their efforts to have the language capabilities of their 

employee base reflect the diversity of their customer base and to develop products and services 

with that customer base in mind. For example, one institution mentioned that 80 percent of its 

branch staff is bilingual. This institution provides forms to consumers in English, but offers 

translations online in Chinese and Spanish.

3.2 Centralized point of contact for technical 

assistance

Many of the larger institutions that provide language services indicated they have a central point 

of contact for technical assistance to help the institution’s employees address any matters 
19 CONSUMER FINANCIAL PROTECTION BUREAU

related to language. While this central group or office may have a variety of functions across 

institutions, commonalities include providing subject matter expertise on relevant laws and 

regulations and developing translation and interpretation frameworks and processes.

The central point of contact is often used to discuss, document, and evaluate policies on a 

regular basis for any business lines that provide products and services in one or more nonEnglish languages. This group or office may also conduct annual reviews for improving and 

refining relevant processes and procedures. 

At some larger institutions, this central point of contact may also provide assistance to the 

institution as it evaluates which areas of its business would most benefit from LEP services. This 

could include the products and the stage in those products’ lifecycles where language services 

might provide the greatest value for LEP consumers. 

Depending on the institution, this central point of contact may develop quality control 

mechanisms for interpretation and/or translation. For example, the point of contact may 

conduct quality assurance testing and monitoring of customer assistance provided in languages 

other than English.

Across the larger institutions that use a central point of contact, this group or office generally 

establishes translation and interpretation policies, including legal review of written documents 

(if available); manages glossaries of financial terms; establishes methods to validate translation;

and provides vetting of third-party providers, among other functions. 

3.3 Translation and interpretation systems

Most of the large financial institutions that provide language services have systems to ensure 

consistency and accuracy of translation and interpretation. The institutions with such systems

have established protocols to ensure that translations are accurate, culturally appropriate, and
20 CONSUMER FINANCIAL PROTECTION BUREAU

at the proper reading comprehension level for the intended audience. In addition, many of these 

institutions either have developed or use publicly-available bilingual glossaries to ensure that 

terms, including technical financial terms, are translated appropriately and consistently.

Regarding translations, several interviewees indicated their preference for “transcreation” which 

is translating for meaning, rather than word-for-word.24 For some institutions, the practice of 

back-translation is a way to validate third-party translations. Back-translation involves taking a 

translated document and having another party translate it back to English to confirm the 

accuracy of the translated document. Some institutions noted limitations of using backtranslation, citing that necessary context can sometimes be lost. 

Some larger institutions also use technology to assist with translation consistency, such as 

translation memories, which store previously-translated text and can ensure that the specific 

terms are appropriately and consistently translated based on an established glossary of terms. 

These institutions indicated that, over time, using translation memories can lead to long-term 

cost efficiencies. Some institutions also noted that while technology has increased the ease with 

which translated documents can be produced, it is still important to have certified professionals

provide quality reviews.

Regarding interpretations, some institutions have established internal standards for oral

support to LEP consumers, such as having certified interpreters and a glossary of terms for 

verbal consistency, among others. Many institutions also noted that they contract with a thirdparty vendor to provide interpretation for other languages. For languages other than Spanish, 

most assistance is provided via third-party interpreters. 

 

24 While most dictionaries have not yet added the word “transcreation,” the term is used to describe the process of

developing materials that are culturally relevant. The goal of “transcreation” is to translate from a source language 

to a target language while maintaining the original intent and context. See The ATA Chronicle, Culturally Capable 

Translations: The Essential Role of Culture in Translation Quality Processes (2007), available at

http://www.atanet.org/chronicle-online/wpcontent/uploads/3603_20_nataly_kelly_darci_graves_rocio_txabarriaga.pdf.
21 CONSUMER FINANCIAL PROTECTION BUREAU

While interpretation and translation certification programs are generally available, the CFPB

learned that the number of certified professionals, particularly for languages other than Spanish 

is low. Some of the institutions indicated that there are no nationally-recognized organizations 

that manage interpreter and translator certification with a specialty in financial terms. By 

comparison, the healthcare industry has language assistance through nationally-certified 

interpreters in several languages.25

3.4 Training and support for staff and 

contractors

Some institutions hire employees who possess foreign language fluency, cultural competency, or

financial expertise. These employees may serve as an internal voice for the organization on 

language-related activities. These employees are also often trained to ensure that other staff are 

able to communicate effectively to LEP customers about the financial products and services 

offered by the institution.

A subset of institutions providing language services require that anyone communicating in a

language other than English is either externally- or internally-certified on both written and 

verbal competency. Other institutions have an in-depth interview process for candidates who 

may provide bilingual services. Some institutions that hire bilingual agents use scripts in specific

languages to facilitate conversations with customers. 

 

25 Certified Languages International, Input for FHFA: Improving Language Access in Mortgage Lending and 

Servicing (2017).
22 CONSUMER FINANCIAL PROTECTION BUREAU

3.5 Interactions with consumers

For institutions that provide language services, the CFPB found a range of approaches to

interacting with LEP consumers in their preferred language in different settings. 

Many institutions expressed awareness of the connection between language and culture, and

recognized the importance of cultural competency in providing information to LEP populations.

Separately, institutions cited concerns about maintaining the confidentiality and security of 

customer information when choosing a third-party language service provider. They also 

indicated that the pool of translation and interpretation companies that can fulfill requirements 

for confidentiality, customer security, and scale is small. 

For some institutions, if a consumer indicates a preference for Spanish on an application in a 

particular line of business (e.g., credit cards), all future communications will be conducted in 

Spanish, as available. These communications include onboarding, servicing, and customer 

management. One institution indicated that Spanish-serviced accounts have high levels of 

customer satisfaction.

3.5.1 Digital settings, such as ATMs, websites, and mobile

applications

Many institutions that provide language services allow customers to choose a language 

preference at an ATM, on their websites, or on their mobile apps, and save that preference for 

subsequent use. Some use disclosures and other forms of messaging to inform customers and 

set expectations when some pages of the website are not available in the preferred language.

The level at which institutions offer translated versions of their websites varies. Some 

institutions offer a fully translated website, while others offer translated versions of some 

portions of their website. For example, some institutions have a Spanish option for secure sites 

that are accessible for existing customers to view their account information. One institution 

indicated that it offers translations online in Chinese as well as in Spanish.
23 CONSUMER FINANCIAL PROTECTION BUREAU

3.5.2 Verbal interactions, such as in-person or over the 

phone

Most institutions that provide language services offer some level of oral support via bilingual 

staff, a third-party phone interpreter service, or both.

For institutions that use a third-party phone interpreter service, staff provide flyers in other 

languages to the LEP customer to explain that he or she will receive language support through 

an interpreter or from a call center. 

Some institutions have a dedicated number for Spanish speakers to call or sophisticated routing 

systems to ensure that LEP customers reach a bilingual agent or language line.

3.5.3 Written documents

Some institutions that offer language services provide customers with translations of certain

documents in languages other than English, including monthly statements, privacy notices, or

other correspondence. Most of the institutions the CFPB spoke to indicated that they provide 

contracts only in English.
24 CONSUMER FINANCIAL PROTECTION BUREAU

4. Conclusion

Entities in the financial industry serve consumers with limited English proficiency using a 

variety of approaches. The CFPB is sharing common themes and resources gathered from 

various stakeholders in order to provide an overview of some of the current practices for serving

LEP consumers. Interviews with financial institutions of various sizes, nonprofit organizations,

and government agencies, in addition to secondary research, informed the common themes 

identified by the CFPB. 

The CFPB encourages the financial services industry to continue to explore ways to expand, 

innovate, and improve the service it provides to consumers with limited English proficiency. The 

CFPB also looks forward to learning more about how the industry is serving the LEP population 

and welcomes financial institutions to engage further with the CFPB on this topic.
25 CONSUMER FINANCIAL PROTECTION BUREAU

APPENDIX A: LEP RESOURCES

Federal interagency LEP 

website

 Language Map App: An interactive mapping tool that helps users find out the

concentration of and languages spoken by LEP individuals in a community, available at

https://www.lep.gov/maps/.

 Before You Hire - Ask Yourself: What Are My Project’s Language Needs?: A workflow 

chart for making language service hiring decisions, available at 

https://www.lep.gov/resources/resources.html. 

 Hiring the Right Telephonic Interpretation Vendor: A process flow for finding a highquality telephone interpretation vendor, available at 

https://www.lep.gov/resources/resources.html.

 Working with Telephone Interpreters: A tool for planning, placing, and troubleshooting 

phone-calls with telephone interpreters, available at 

https://www.lep.gov/resources/resources.html.

 What Does It Mean to Be a Certified Linguist?: A resource outlining the qualifications

for a certified interpreter or translator, available at 

https://www.lep.gov/resources/resources.html.

 Building an Effective Staff Language Service Program: A publication for recruiting, 

hiring, assessing, and retaining staff linguists, available at 

https://www.justice.gov/crt/file/923341/download.
26 CONSUMER FINANCIAL PROTECTION BUREAU

Bilingual glossaries

 CFPB glossaries: English-Spanish financial terms and English-Chinese financial terms. 

In 2015, the CFPB published its glossaries of financial terms translated from English into 

Spanish and Chinese as a resource tool. Stakeholders that may be interested in using this 

tool include, but are certainly not limited to, financial educators, government agencies, 

financial service providers, and other organizations serving LEP consumers. The glossary 

of terms is not a mandate, guidance, or a requirement. The English-Spanish glossary is 

available at https://www.consumerfinance.gov/documents/5542/cfpb_adult-fined_spanish-style-guide-glossary.pdf, and the English-Chinese glossary is available at 

https://www.consumerfinance.gov/documents/5540/cfpb_adult-fin-ed_chinese-styleguide-glossary.pdf.

 Housing and Urban Development glossary: Spanish-English dictionary. The dictionary 

is available at 

https://portal.hud.gov/idc/groups/public/documents/hudgov_html/main_terms_span.

html.

Forms and disclosures

 Fannie Mae and Freddie Mac provide lenders with Spanish translations of a loan 

application, loan estimate, verification forms, closing disclosures, and a sample adverse 

action notice. The translations provided by Fannie Mae can be found at 

https://www.fanniemae.com/singlefamily/spanish-resources-for-lenders and 

https://www.fanniemae.com/singlefamily/spanish-resources-for-servicers. The 
27 CONSUMER FINANCIAL PROTECTION BUREAU

translations provided by Freddie Mac can be found at 

http://www.freddiemac.com/uniform/spanish.html.

 A few of the CFPB’s major rules address language access by, in accordance with preexisting law, permitting required disclosures to be provided in a language other than 

English, as long as the disclosures are also made available in English.26 A few other CFPB

rules provide more specific guidance about facilitating access for LEP consumers to 

markets for consumer financial products and services and helping ensure that such 

markets are fair, transparent, and competitive. For example, the CFPB’s TILA-RESPA 

Integrated Disclosure (TRID) Rule explicitly permits creditors to translate certain 

mortgage disclosures into languages other than English and provides consumer-tested 

Spanish language translations of those mortgage disclosures.27 Pursuant to the DoddFrank Act, the CFPB’s Remittance Transfer Rule provides that certain advertising, 

soliciting, or marketing of remittance transfer services in a foreign language triggers the 

requirement to provide remittance disclosures in that language.28 The CFPB’s Prepaid 

Rule similarly provides that principally using a foreign language to, among other things, 

advertise, solicit, or market a prepaid account may trigger a requirement to provide 

certain disclosures in that language.29

 The Dodd-Frank Act amended the Real Estate Settlement Procedures Act (RESPA) to, 

among other things, provide that the Director shall “prepare the [home buying 

information] booklet in various languages and cultural styles, as the Director determines 

 

26 See, e.g., 12 C.F.R §§ 1002.4(e) (Regulation B), 1005.4(a)(2) (Regulation E), 1024.32(a)(2) (Regulation X), and 

1026.27 (Regulation Z). Most Bureau regulations may be found at https://www.consumerfinance.gov/eregulations/.

27 See 12 C.F.R. §§ 1026.37(o)(5)(ii), 1026.38(t)(5)(viii), and App. H-28.

28 See 12 C.F.R. § 1005.31(g).

29 See 81 FR 83934, 84334 (Nov. 22, 2016) (to be codified at 12 C.F.R. § 1005.18(b)(9)); see also 82 FR 18975 (Apr. 25, 

2017).
28 CONSUMER FINANCIAL PROTECTION BUREAU

to be appropriate, so that the booklet is understandable and accessible to homebuyers of 

different ethnic and cultural backgrounds.”30

Financial education resources

 Ask CFPB: An interactive online tool that gives consumers answers to questions about 

financial products and services, including credit cards, mortgages, student loans, bank 

accounts, credit reports, payday loans, and debt collection. Ask CFPB is available in 

Spanish at consumerfinance.gov/es/obtener-respuestas/. 

 CFPB brochures: The CFPB has created a range of publications for consumers that 

provide straightforward information about money management and other financial 

issues. These publications include brochures about accounts, credit, money 

management, mortgages, and other topics. The CFPB makes many of these resources 

available in English and Spanish as well as many of them in eight other languages. The 

CFPB provides them for download or free bulk ordering at 

pueblo.gpo.gov/CFPBPubs/CFPBPubs.php.

 CFPB en Español: CFPB en Español provides Spanish-speaking consumers a central 

point of access to the CFPB’s most-used consumer resources that are translated into 

Spanish. This page offers:

 Ask CFPB en Español.

 

30 See 12 U.S.C. § 2604(a).
29 CONSUMER FINANCIAL PROTECTION BUREAU

 A consumer complaints page that highlights the complaint process and the phone 

number consumers can call to submit a complaint in Spanish.

 An About Us page with Spanish-language videos and introductory content about how 

the CFPB works to protect consumers.

 A home page that offers details on the CFPB’s resources for consumers in search of a 

mortgage and those who already own a home. CFPB en Español can be found at 

consumerfinance.gov/es/.

 Your Home Loan Toolkit: The Dodd-Frank Act amended the Real Estate Settlement 

Procedures Act (RESPA) to, among other things, provide that the Director shall “prepare 

the [home buying information] booklet in various languages and cultural styles, as the 

Director determines to be appropriate, so that the booklet is understandable and 

accessible to homebuyers of different ethnic and cultural backgrounds.” To support this 

mandate, the toolkit is available in Spanish and guides consumers through the process of 

shopping for a mortgage and buying a home. The Spanish guide can be found at 

files.consumerfinance.gov/f/201507_cfpb_your-home-loan-toolkit-web-spanish.pdf.

 Remittances: The CFPB’s first substantive rule provides important consumer protections 

to users of international money transfers, or remittances. The CFPB developed materials 

to educate consumers about the protections for remittance transfers. These materials are 

available in English, Spanish, Haitian Créole, Chinese, and Tagalog and include fact 

sheets, flyers, posters, and brochures. The CFPB provides them for download or free bulk 

ordering at pueblo.gpo.gov/CFPBPubs/CFPBPubs.php.

 Financial Education Programs Serving Immigrant Populations Field Scan: The Office 

of Financial Education conducted a field scan of programs, practices, and initiatives that 

serve immigrant populations to help inform the CFPB’s financial education initiatives 

and to raise visibility about the financial education challenges that many immigrants 

face. The field scan outlines promising financial education strategies that financial 

education providers can use to better serve immigrants who seek their services and are 

part of their communities. The ultimate goal is to help consumers achieve their own 

financial goals. The field scan was released in summer 2016 and can be found at 

consumerfinance.gov/data-research/research-reports/financial-education-programsserving-immigrant-populations/.