Supporting Persons with Limited English Proficiency (LEP)
Community Good Episcopal Federal Credit Union is committed to providing reasonable accommodations to members with LEP to the extent required by federal law. To ensure that such persons have reasonable access to support, Community Good Episcopal FCU will follow the procedure below when serving persons with LEP.
- IDENTIFYING SERVICES TO BE PROVIDED
NYE FCU will initiate reasonable steps to determine what services should be
provided. NYE FCU will make that determination by assessing the following
factors:
(i) The number of LEP persons likely to seek services from the credit union;
(ii) The frequency with which those LEP individuals are likely to seek services from
the credit union;
(iii) the nature and importance of the services the LEP persons are likely to seek;
and
(iv) the resources available to the credit union along with the cost of translation. - PROVIDING WRITTEN TRANSLATIONS
Management will determine what vital documents should be translated and the
language(s) of translation. When making this determination, management will
consider the four factors above. All translated documents will be provided free of
charge. - PROVIDING INTERPRETATION SERVICES
When oral interpretation is made available, frontline staff will be provided with the
contact information for the interpreter. If the interpreter is on staff, then the name,
language, and phone number of the bilingual staff person will be provided.
Some LEP persons 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 only after the LEP
person has understood that an offer of an interpreter at no charge to the person has
been made by Community Good Episcopal Federal Credit Union, if such a service is available.
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, the person will not be used as an interpreter.
Children under the age of 16 will not be used to interpret in order to ensure
confidentiality of information and accurate communication. - IDENTIFYING LEP PERSONS AND THEIR LANGUAGE
When a LEP service is made available, NYE Federal Credit Union will identify the
language and communication needs of each LEP person who may benefit from the
LEP service as the person seeks service. If necessary, staff will use a language
identification card (or “I speak cards,” available online at http://www.lep.gov) or posters to
determine the language. In addition, when records are kept of past interactions with
clients, the language used to communicate with the LEP person will be included as
part of the record and noted on the member’s account. - PROVIDING NOTICE TO LEP PERSONS
When LEP assistance is made available, Community Good Episcopal Federal Credit Union will inform LEP persons of the availability of the language assistance, free of charge, by providing
written notice in languages LEP persons will understand. Such notices and signs will
be posted and provided in intake areas and other points of entry. Notification may also
be provided through one or more of the following: the credit union’s website, outreach
documents, telephone voicemail menus, local newspapers, radio and television
stations, and/or community-based organizations.