Cooperative Federal is dedicated to providing inclusive and equitable financial services. The following policy guides our Language Assistance Plan for serving persons with Limited English Proficiency (LEP).
a) Data collection. Cooperative Federal will proactively collect information on LEP status and language assistance needs using the following methods:
i) Applications for accounts and loans. Application forms (print and digital) for Credit Union services shall collect information regarding primary language spoken. This data shall be stored in Cooperative Federal’s core system for member service, LAP analysis, and other recordkeeping purposes.
ii) Development service intake. Enrollment forms for Housing Counseling, Financial Counseling, and Business Advising services shall collect information regarding primary language spoken. This data shall be stored in case files and/or Client Management Systems (CMS) for service delivery, LAP analysis, and other recordkeeping purposes.
iii) “I Speak” cards. Credit Union branch locations shall supply bilingual “I Speak” cards enabling members to self-identify their language assistance needs. When members present these cards to Cooperative Federal staff, their records shall be updated in our core system member service, LAP analysis, and other recordkeeping purposes.
b) Notifications. Cooperative Federal shall post notices in commonly encountered languages notifying LEP persons of language assistance and encouraging them to self-identify.
i) Notification locations. Notifications shall be posted on our website and in Credit Union lobbies.
ii) Determining commonly encountered languages. Commonly encountered languages shall be identified using the data collection methods described in LAP Section 1(a); demographic data for our target market and/or service area derived from US Census Bureau or other reliable sources; and/or feedback from staff that frequently interact with LEP members/clients.
a) Commonly encountered languages. Cooperative Federal’s languages services shall give primacy to the following commonly encountered languages, as determined pursuant to LAP Section 1:
i) Tier 1. Spanish
ii) Tier 2. Arabic, Swahili, Somali, and French.
b) Types of language services available. Cooperative Federal shall provide members and potential members with the following services free of charge, to enable them to access our financial products and services as well as our development services.
i) Phone or video interpretation. Available on-demand and by appointment for services delivered in person, by phone, or remotely (e.g. video conference); 200+ languages supported.
ii) In-person interpretation. Available by appointment for services delivered in person, by phone, or remotely (e.g. video conference); “Tier 1” and “Tier 2” languages supported (see LAP Section 2(a)) at minimum.
iii) Translation of literature. Cooperative Federal will make every effort to provide outreach materials, application forms, and other key documents in multiple languages; “Tier 1” languages supported (see LAP Section 2(a)).
c) Obtaining language services. Credit Union personnel shall have access to language services information and procedures via the staff Intranet, including the following information:
i) Approved language service providers. Contact information, types of services offered, languages supported, and booking protocol.
ii) Internal point-of-contact. Name and title for the Credit Union’s language services coordinator.
d) Responding to LEP persons. Language services procedures, available on the staff Intranet, shall include guidelines for interacting with and responding to LEP persons.
i) Phone calls. Credit Union personnel shall attempt to connect the caller with in-house interpreters, if applicable. If that is not possible in a timely manner, “on demand” interpretation services (by Phone) may be used.
ii) In-person interactions. Credit Union personnel shall attempt to direct the LEP individual to in-house interpreters, if applicable. If that is not possible in a timely manner, instant or walk-in services requests shall receive “on demand” interpretation services (by Phone or Video); and appointments scheduled 2 or more days in advance shall receive Phone, Video, or In Person interpretation services as appropriate based on the nature and duration of the appointment.
iii) Written communications. Credit union personnel shall redirect the communication to in-house interpreters/translators, if applicable. If that is not possible, staff should attempt to contact the LEP person by phone with an interpreter on the line.
e) Ensuring competency of interpreters and translation services. The Credit Union’s language services coordinator shall be responsible for identifying and approving competent language service providers. The vetting process for outside service providers shall include referrals from community partners or public agencies that service LEP populations, and/or review of applicable professional certifications and credentials. Credit Union personnel that are fluent in languages spoken by LEP persons may also be authorized to deliver language services.
a) Policy training. All Cooperative Federal employees will receive training on the Credit Union’s Language Assistance Policy. Training will occur at the following times:
i) During New Employee Orientation.
ii) Whenever the Policy is revised or updated.
b) Operating procedures. Front-line and management staff shall receive training on Cooperative Federal’s Language Assistance Measures on an annual basis, at minimum. Additional training shall be provided as needed in response to changes in a staff member’s role, revisions to Credit Union policy, or supervisory oversight and performance reviews.
a) Multilingual notifications. Notices of language services shall be communicated in “Tier 1” and “Tier 2” languages (see LAP Section 2(a)) at minimum.
b) Notification locations. Notifications shall be posted, at minimum, on our website and in Credit Union lobbies.
c) Community outreach. Cooperative Federal shall actively work to engage community partners that serve LEP audiences, and to incorporate language service notifications in educational and promotional materials.
a) Frequency. Cooperative Federal shall review and update the Language Assistance Plan not less than biannually.
b) Authority. The Credit Union’s language services coordinator is responsible for monitoring and updating the Language Assistance Plan, personally or by delegating as appropriate; supervised by the CEO.