We’ve blogged about competent human translators and their role in the process of identifying the products, which qualify for the “Made in the USA” label, as well as the importance of professional translation services for communication with the non-English-speaking consumers. One translation-related question often arises in connection with foreign language disclosures.
Question: Are disclosures made in a foreign language binding?
Answer: It depends on the regulation that the required disclosure is being made under. For example, under Regulation Z of the Truth in Lending Act (12 CFR 226.27) disclosures made in a language other than English are allowed.
However, according to this regulation, an English translation of the foreign language disclosures must be made available upon a customer’s request.
It must be noted, however, that this rule does not apply to sections 226.16 and 226.24 – both of which pertain to advertisements – and require the use of English language disclosures, even if done in conjunction with a foreign language disclosures.
Further, just because an initial disclosure is made in English does not mean that subsequent disclosures also be in English. Thus, Company A can make an initial disclosure in English and then a subsequent disclosure in Spanish- as long as the English language translation is provided upon request.