Policy Statement
As a community bank, FNB Oxford Bank (FNB or bank) is committed to helping the entire community with banking services and products. To that end, we understand that there may be a portion of our community with limited English proficiency (LEP) and may be in need of assistance when entering the bank. It is the policy of FNB to provide effective and meaningful access to LEP persons to all of our products and services. Our personnel shall offer free language assistance services to LEP individuals whom they encounter or whenever an LEP person requests language assistance services. FNB and its personnel will provide general information to members of the public that language assistance services are available free of charge to LEP individuals.
Purpose and Authority
The purpose of this plan is to establish effective guidelines, consistent with Title VI of the Civil Rights Act of 1964, for FNB personnel to follow when providing services to, or interacting with, individuals who have limited English proficiency (LEP). It is the policy of FNB to not discriminate against any person who is LEP. FNB will take all reasonable steps to provide LEP persons with meaningful access to program information through our website or upon request. Following these guidelines is essential to the success of our mission to improve social and economic conditions for residents and businesses in our communities in North Mississippi by offering financial products and development services tailored to their unique needs.
Steps Taken to Develop a Plan for Language Assistance
- Assessment to understanding how LEP individuals interact with the bank
- Identifying and assessing LEP communities and their needs
- Reviewing and analyzing options for providing language assistance services
- Training staff on policies and procedures
- Providing notice of language assistance services
- Monitoring, evaluating, and updating language access policy directives, plans, and procedures.
Assessment of Language Assistance Needs
Based upon our assessment, the volume of LEP in our community and at our bank is relatively small considering our experience with bank customers and the demographics data from the U.S. Census Bureau. FNB estimates that about 1% or less of our customers are LEP individuals, and that is certainly consistent with the U.S. Census Bureau data regarding the number of people that speak English less than “very well” in Lafayette and surrounding counties in Mississippi (anywhere from less than 1% to 3% depending on the region).
FNB’s interaction with the public is mainly in our retail space and with retail and lending personnel. Spanish is the primary language encountered at FNB for LEP individuals. They will most often need verbal assistance with interpretation.
Language Assistance Measures
FNB has one employee who is bilingual and fluent in Spanish[1] and is available as needed to assist LEP customers with Spanish. Our staff will know about her availability to assist in translation. The bank also utilizes a third-party vendor to provide language assistance services to LEP individuals on an as-needed basis. FNB anticipates that the need for these services will be minimal given our demographics and customer experience; accordingly, we believe one in-house translator and the availability of a third-party contracted interpreter should sufficiently and reasonably address the LEP needs. The third-party contracted interpreter will be able to assist customers with Spanish, American Sign Language, and other languages as well. Written interpretation needs will be assessed and addressed as needed. Our retail and lending personnel are trained to be watchful for LEP needs and quickly respond to customers needing or requesting LEP assistance. FNB displays notices in the entry way or lobby of the branches notifying customers of this service. These services will be provided free of charge to customers.
Staff Training and Responsibility
FNB will provide guidance and information to frontline staff (universal bankers and lenders) and managers regarding FNB’s mission and responsibility to LEP individuals through distribution of our language assistance plan, staff training, and orientation sessions. The training will include simple instructions to staff on how to access and use the third-party vendor translation services. Our vendor is able to help the bank track the number of language requests received. Our CDFI Coordinator and/or Human Resources Director will help oversee the implementation of the Language Assistance Plan, who will also coordinate with the Chief Banking Officer, the Retail Manager, and the LAP Coordinator. K. Keller, located in the South Lamar Oxford branch, is the LAP Coordinator and may be contacted at LAPC@fnboxford.com. FNB will assess on an annual basis language assistance needs and measures for their effectiveness and efficiency.
Notice of Language Assistance Services
FNB will provide notice of language assistance services through written/bilingual notices in the entry way or lobby of the branches notifying customers of this service. This information will also be displayed near service stations of universal bankers and others. The bank will also post a copy of this plan and other information on our website.
Monitoring, Evaluating, and Updating the Language Access Policy Directives, Plans, and Procedures
Our staff responsible for overseeing and implementing our Language Assistance services (LAP Coordinator, CDFI Coordinator and HR Director) will be engaged in the following:
- Annually reviewing processes and procedures for use of non-English languages
- Evaluating which areas of business would most benefit from LEP services
- Developing quality control mechanisms in the current language assistance plan and measures taken and used
- Establishing any changes or updates to the language assistance plan
[1] As the need for Language Assistance services increases, FNB will implement an increased emphasis on looking for candidates who are bilingual.