Policy
First Southwest Bank will take reasonable steps to ensure that persons with Limited English Proficiency (LEP) have meaningful access and an equal opportunity to participate in our banking service and products. The policy of First Southwest Bank is to ensure meaningful communication with LEP customers and their authorized representatives involving their banking and financial needs.
The policy also provides for communication of information contained in vital documents, including but not limited to, banking and financial forms, lending and deposit documents and new account receipts. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the customer.
Language assistance will be provided through the use of competent bilingual staff and/or staff interpreters. All staff will be provided notice of this policy and procedure, and staff that may have direct contact with LEP individuals will be trained in effective communication techniques, including the effective use of an interpreter.
First Southwest Bank will conduct a regular review of the language access needs of our customer population, as well as update and monitor the implementation of this policy and these procedures, as necessary.
Procedures
Identifying LEP Persons and their Language
First Southwest Bank will promptly identify the language and communication needs of the LEP person. If necessary, staff will use a language identification card (or “I speak cards,” available online at www.lep.gov) or posters to determine the language. In addition, when records are kept of past interactions with customers, the language used to communicate with the LEP person will be included as part of the record.
Obtaining a Qualified Interpreter
The Director of Compliance is responsible for:
- Maintaining an accurate and current list showing the name, language, phone number, branch, and hours of availability of bilingual staff
- Contacting the appropriate bilingual staff member to interpret, in the event that an interpreter is needed, if an employee who speaks the needed language is available and is qualified to interpret.
- Obtaining an outside interpreter if a bilingual staff or staff interpreter is not available or does not speak the language needed.
- Some LEP people may prefer or request to use a family member or friend as an interpreter. However, family members or friends of the LEP person will not be used as interpreters unless specifically requested by that individual and after the LEP person has understood that an offer of an interpreter at no charge to the person has been made by First Southwest Bank. Such an offer and the response will be documented in the person’s file. If the LEP person chooses to use a family member or friend as an interpreter, issues of competency of interpretation, confidentiality, privacy, and conflict of interest will be considered. If the family member or friend is not competent or appropriate for any of these reasons, competent interpreter services will be provided to the LEP person.
Providing Written Translations
- When translation of documents is needed, the First Southwest Bank employee will submit documents for translation into frequently encountered languages to the Director of Compliance. Original documents being submitted for translation will be in final, approved form.
- First Southwest Bank will provide translation of other written materials, if needed, as well as written notice of the availability of translation, free of charge, for LEP individuals.
- First Southwest Bank will set benchmarks for the translation of vital documents into additional languages over time.
Providing Notice to LEP Persons
First Southwest Bank will inform LEP people of the availability of language assistance, free of charge, by providing written notice in languages LEP people will understand. At a minimum, notices and signs will be posted and provided in each branch with other compliance and regulatory related signage.
Monitoring Language Needs and Implementation
On an ongoing basis, First Southwest Bank will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, First Southwest Bank will regularly assess the efficacy of these procedures, including but not limited to mechanisms for securing interpreter services, equipment used for the delivery of language assistance, complaints filed by LEP people, feedback from customers, etc. Reporting will be made available to the First Southwest Bank Board of Directors.