Does anyone have any experience/insights with translating their disclosures and other materials? If you have used a vendor in the past, I would also love to hear about your experience

This is definitely a need but not a lot of guidance out there and wanted to get some perspectives of how they've gone about doing so.

Some general thoughts:
- If using a third-party vendor, would obviously have to handle in accordance with safe CMS standards
- What certifications would a regulatory agency find necessary if we were to hire a translating service?
- If we use our existing disclosure vendor, cost seems exorbitant
- Is there a regulatory concern if the branches have multi-language disclosures, but perhaps do not have an employee who speaks the language?
- FHFA does have this Language Translation Disclosure for borrowers about language-related services for mortgage transactions. https://www.fhfa.gov/mortgage-translations/language-translation-disclosure


Any help is greatly appreciated!

It can be a slippery slope. If you choose to go that route, you need a formal, well documented approach. If you have not read this document, it would be a good place to start: https://files.consumerfinance.gov/f/documents/cfpb_lep-statement_2021-01.pdf

my somewhat faulty memory seems to recall that there was once guidance that if you are handing out disclsoures in a foreign language you had to be able to have someone that also spoke that language available to assist those (potential) customers. perhpas an OCC guidance...

The CFPB does not say that directly in that release, but you have to have a communication plan in place and communicate what you are willing to do. It would seem silly to create non-English disclosures if no one in the bank could speak to customers in the language included in the disclosures.

"Financial institutions may mitigate certain compliance risks by providing LEP consumers with clear and timely disclosures in non-English languages describing the extent and limits of any language services provided throughout the product lifecycle.

In those disclosures, financial institutions may provide information about the level of non-English language support as well as communication channels through which LEP consumers can obtain additional information and ask questions."