Comment Number: 515567-00001
Received: 3/23/2005 3:56:12 PM
Organization:
Commenter: Robert Braun
State: FL
Agency: Federal Trade Commission
Rule: Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA)
Docket ID: 3084-AA99
No Attachments

Comments:

The proposal makes no reference to the language to be used in the disclosures. No doubt most of the institutions in Puerto Rico use documents printed in the Spanish language. Certainly some of the customers in Puerto Rico do not understand English. This may also be true in many areas within the 50 States. I suggest that you require disclosures to be either in the same language as the advertisement, signature card, etc. or require the disclosures to be set forth in both English and Spanish in areas where the customers primarily speak Spanish. You should supply the Spanish translations, to avoid any possible misunderstanding that might result from a faulty translation by the advertiser or bank.