1. Limited English Proficiency ("LEP")
Vaishali S. Rao
Partner, Regulatory & Compliance

2. LEP Basics What Is It? Who Is Interested? What Are They Interested In?
CFPB, NYC Department of Consumer Affairs, AG's
What Are They Interested In?
Fair Lending (ECOA disclosures)
UDAAP (disclosures, documents, translators)
1) Consent with CFPB – lender excluded Spanish-speaking consumers from debt repayment and settlement offers
2) Deceptive telemarketing of ancillary products to Spanish-speaking consumers.
April 2015 Fair Lending Report – encourages lenders to provide assistance to LEP individuals and to increase access to credit or ask for help in finding ideas of how to promote access

3. What Can You Do? LEP Audit Is IVR enough
What languages? What versions of what languages?
LEP through your customer life cycle
Is IVR enough
Marketing Match Servicing and Support
Disclosures
BE: Prepared, Sensitive, Consistent, Realistic, Listening, Local, Aware

4. Who's Paying? Student Loan Employment Benefit

5. FinTech & the Future FutureFuel Gradfin Peanut Butter Tuition.io …More
??% of millennials would commit to an employer for 5 years if the company helped pay back their student loans.
??% of young workers would take advantage of a sign-on bonus targeted at paying back student loans.
??% would take advantage of a match for student loan repayments similar to a 401(k) match.
FutureFuel
Gradfin
Peanut Butter
Tuition.io
…More
86; 93; 92

6. CFPB Report
Outdated technology that makes processing payments "unnecessarily complicated."
Inability to accept electronic payments
Inability to accept "batch payments" on behalf of hundreds or even thousands of employees
Borrowers are often making payments on multiple student loans. Employers lack access to information about their employee's student loans such as loan balances, interest rates, and repayment plan information.

7. 3rd Party Payor Issues To Consider
Disclosures
Privacy
Borrower choice
Timely & Accurate Payment Processing
Paid Ahead
Coordination of communication to borrowers
Communication to borrowers existing the benefit

8. Vaishali S. Rao Hinshaw & Culbertson LLP Office 312-704-3156 vrao@hinshawlaw.com www.hinshawlaw.com