What “safe harbors” may recipients follow to ensure they have no compliance finding with Title VI LEP obligations?
HUD has adopted a “safe harbor” for translation of written materials. The Guidance identifies actions that will be considered strong evidence of compliance with Title VI obligations. Failure to provide written translations under these cited circumstances does not mean that the recipient is in noncompliance. Rather, the “safe harbors” provide a starting point for recipients to consider: Whether and at what point the importance of the service, benefit, or activity involved warrants written translations of commonly used forms into frequently encountered languages other than English; Whether the nature of the information sought warrants written translations of commonly used forms into frequently encountered languages other than English; Whether the number or proportion of LEP persons served warrants written translations of commonly used forms into frequently encountered languages other than English; and Whether the demographics of the eligible population are specific to the situations for
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