Whether you must provide a sign language interpreter in this case depends on whether your bank determines such an interpreter is necessary to communicate effectively with the customer.

Under the Americans With Disabilities Act, places of public accommodation (including banks) must provide auxiliary aids and services when necessary to communicate effectively with people who have communication disabilities. The type of aid necessary for effective communication will vary according to the type of communication used by the individual, the nature, length, and complexity of the communication involved, and the context in which the communication is taking place.

In many cases, more than one type of aid or service may make effective communication possible. encourages your bank to consult with the individual with the disability to determine what type of aid would be appropriate. Ultimately, though, the decision as to what measures to take rests with your bank, provided that the method you choose results in effective communication.

In this case, you have indicated that you may be able to communicate effectively with the customer about opening an account without using an interpreter. If so, you are not required to provide a sign language interpreter.

For resources related to our guidance, please see:

• 28 CFR 36.303(c) (“A public accommodation shall furnish appropriate auxiliary aids and services where necessary to ensure effective communication with individuals with disabilities. This includes an obligation to provide effective communication to companions who are individuals with disabilities.”)

• 28 CFR 36.303(c)(ii) (“The type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place.”)

• 28 CFR 36.303(c)(ii) (“A public accommodation should consult with individuals with disabilities whenever possible to determine what type of auxiliary aid is needed to ensure effective communication, but the ultimate decision as to what measures to take rests with the public accommodation, provided that the method chosen results in effective communication. In order to be effective, auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability.”)

• ADA Title III Technical Assistance Manual (“Who decides what type of auxiliary aid should be provided? Public accommodations should consult with individuals with disabilities wherever possible to determine what type of auxiliary aid is needed to ensure effective communication. In many cases, more than one type of auxiliary aid or service may make effective communication possible. While consultation is strongly encouraged, the ultimate decision as to what measures to take to ensure effective communication rests in the hands of the public accommodation, provided that the method chosen results in effective communication.”)