We are not aware of any Illinois laws requiring banks to provide documents in languages other than English, with three exceptions: there are two residential mortgage foreclosure documents that must be provided in multiple languages, and certain disclosures must be made when using an interpreter to conduct banking transactions.

When filing a foreclosure action against a residential mortgage loan customer in Illinois, your bank must attach a Homeowner Notice to the foreclosure summons that is in both English and Spanish. In addition, the City of Chicago requires any purchaser of residential rental property in a foreclosure sale (including a bank purchasing the property as the credit bidder) to provide a tenant’s rights notice in English, Spanish, Polish, and Chinese.

As for using interpreters, the Illinois Banking Act expressly permits banks to conduct banking transactions through interpreters, while the Consumer Fraud and Deceptive Business Practices Act imposes disclosure requirements for the use of an interpreter when a transaction or negotiations over a transaction are conducted in a language other than English.

For resources related to our guidance, please see:

• Regulation Z, Official Interpretations, 12 CFR 1026, Paragraph 27, Comment 1 (“If a creditor provides account-opening disclosures in a language other than English, subsequent disclosures need not be in that other language. For example, if the creditor gave Spanish-language account-opening disclosures, periodic statements and change-in-terms notices may be made in English.”)

• Illinois Mortgage Foreclosure Law, 735 ILCS 5/15-1504.5 (“For all residential foreclosure actions filed, the plaintiff must attach a Homeowner Notice to the summons. The Homeowner Notice must be in at least 12 point type and in English and Spanish. The Spanish translation shall be prepared by the Attorney General and posted on the Attorney General's website. A notice that includes the Attorney General's Spanish translation in substantially similar form shall be deemed to comply with the Spanish notice requirement in this Section. The Notice must be in substantially the following form: . . .”) (English and Spanish notices available here)

• Chicago Municipal Code § 5-14-040 (“No later than 21 days after a person becomes the owner of a foreclosed rental property, the owner shall make a good faith effort to ascertain the identities and addresses of all tenants of the rental units in the foreclosed rental property and notify, in writing, all known tenants of such rental units that, under certain circumstances, the tenant may be eligible for relocation assistance. The notice shall be given in English, Spanish, Polish and Chinese and be as follows: . . .”) (English, Spanish, Polish, and Chinese notices available here)

• Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/2N (“If (i) a person conducts, in a language other than English, a retail transaction or negotiations related to a retail transaction resulting in a written contract and (ii) the consumer used an interpreter other than the retailer or an employee of the retailer in conducting the transaction or negotiations, the retailer must have the consumer and the interpreter sign the following forms: . . .”)

• Illinois Banking Act, 205 ILCS 5/5f (“Non-English language transactions. A bank may conduct transactions in a language other than English through an employee or agent acting as interpreter or through an interpreter provided by the customer.”)