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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

May 2010: 

Consumer Finance: 

Factors Affecting the Financial Literacy of Individuals with Limited 
English Proficiency: 

GAO-10-518: 

GAO Highlights: 

Highlights of GAO-10-518, a report to congressional committees. 

Why GAO Did This Study: 

According to Census data, more than 12 million adults in the United 
States report they do not speak English well or at all. Proficiency in 
reading, writing, speaking, and understanding the English language 
appears to be linked to multiple dimensions of adult life in the 
United States, including financial literacy—the ability to make 
informed judgments and take effective actions regarding the current 
and future use and management of money. 

The Credit Card Accountability, Responsibility and Disclosure Act of 
2009 mandated GAO to examine the relationship between fluency in the 
English language and financial literacy. Responding to this mandate, 
this report examines the extent, if any, to which individuals with 
limited English proficiency are impeded in their financial literacy 
and conduct of financial affairs. To address this objective, GAO 
conducted a literature review of relevant studies, reports, and 
surveys, and conducted interviews at federal, nonprofit, and private 
entities that address financial literacy issues and serve people with 
limited English proficiency. GAO also conducted a series of focus 
groups with consumers and with staff at community and financial 
organizations. 

GAO makes no recommendations in this report. 

What GAO Found: 

Staff at governmental, nongovernmental, and private organizations that 
work with non-English speaking populations consistently told us that, 
in their experience, a lack of proficiency in English can create 
significant barriers to financial literacy and to conducting everyday 
financial affairs. For example, service providers and consumers with 
limited English proficiency told us that because most financial 
documents are available only in English, individuals with limited 
English proficiency can face challenges completing account 
applications, understanding contracts, and resolving problems, such as 
erroneous bills. In addition, financial education materials—such as 
print material, Web sites, broadcast media, and classroom curricula—
are not always available in languages other than English and, in some 
cases, Spanish. Further, information and documents related to 
financial products tend to be very complex and can use language 
confusing even to native English speakers. In some cases, written 
financial materials are provided in other languages, but the 
translation may not be clear if it is not written using colloquial or 
culturally appropriate language. Interpretation (oral translation) can 
also be of limited usefulness if the interpreter does not fully 
understand or is not able to explain the material, a problem 
exacerbated by the fact that adults with limited English proficiency 
often receive assistance from their minor children. 

Many factors other than language also influence the financial literacy 
of individuals with limited English proficiency. For example, 
immigrants may lack familiarity with the U.S. financial system and its 
products, which can differ greatly from those in their native 
countries. Cultural differences can also play a role in financial 
literacy because different populations have dissimilar norms, 
attitudes, and experiences related to managing money. For instance, in 
some cultures carrying debt is viewed negatively, which may deter 
immigrants from such cultures from taking loans to purchase homes or 
cars and building credit histories. In addition, some studies have 
reported a correlation between financial literacy and levels of income 
and education. As a result of these issues, some service providers and 
advocates suggested that efforts to improve the financial literacy of 
people with limited English proficiency go beyond translation and also 
address underlying cultural and socioeconomic factors. 

Evidence suggests that people with limited English proficiency are 
less likely than the U.S. population as a whole to have accounts at 
banks and other mainstream financial institutions. They are also more 
likely to use alternative financial services—such as payday lenders 
and check--cashing services—-that often have unfavorable fees, terms, 
and conditions. Further, the Federal Trade Commission and immigrant 
advocacy organizations have noted that some populations with limited 
English language skills may be more susceptible to fraudulent and 
predatory practices. Several service providers we spoke with said that 
financial education can play an important role in helping consumers 
with limited English proficiency avoid abusive and predatory practices. 

View [hyperlink, http://www.gao.gov/products/GAO-10-518] or key 
components. For more information, contact Alicia Puente Cackley at 
(202) 512-8678 or cackleya@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Language Barriers Can Impede Everyday Financial Transactions: 

Many Factors Other Than Language Influence the Financial Literacy of 
Individuals with Limited English Proficiency: 

Consumers with Limited English Proficiency Are More Likely to Use 
Alternative Financial Services and May Be More Susceptible to 
Fraudulent and Predatory Practices: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Examples of Financial Education Targeted at Populations 
with Limited English Proficiency: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Native Languages of U.S. Adults With Limited English 
Proficiency, 2006-2008: 

Figure: 

Figure 1: Proportion of the Adult Population with Limited English 
Proficiency, 2006-2008: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

May 21, 2010: 

The Honorable Christopher J. Dodd: 
Chairman: 
The Honorable Richard C. Shelby: 
Ranking Member: 
Committee on Banking, Housing, and Urban Affairs: 
United States Senate: 

The Honorable Barney Frank: 
Chairman: 
The Honorable Spencer Bachus: 
Ranking Member: 
Committee on Financial Services: 
House of Representatives: 

The United States has a highly diverse population representing 
cultures from all over the world. English is not the primary language 
of many people living in the United States, and significant numbers 
have limited English proficiency--that is, a limited ability to read, 
write, speak, or understand the English language. For example, 
according to 2008 Census statistics, more than 12 million adults 
reported that they do not speak English well or do not speak English 
at all. English language ability appears to be linked to multiple 
dimensions of adult life in the United States, including civic 
participation and workforce participation and mobility. The ability to 
speak English can also affect financial literacy--the ability to make 
informed judgments and take effective actions regarding the current 
and future use and management of money. 

The Credit Card Accountability, Responsibility and Disclosure Act of 
2009 mandated GAO to examine the relationship between fluency in the 
English language and financial literacy.[Footnote 1] This report 
responds to that mandate by examining the extent, if any, to which 
individuals with limited English proficiency are impeded in their 
financial literacy and conduct of financial affairs. To address this 
objective, we conducted a literature review of relevant studies, 
reports, and surveys. We also conducted interviews at and gathered 
related studies and educational materials from federal agencies, 
including the Federal Trade Commission and Department of the Treasury, 
organizations that serve or advocate for populations with limited 
English proficiency, organizations that provide or support financial 
literacy and education, and financial services institutions. We also 
held a series of 10 focus groups, each of which included 5 to 11 
participants and addressed the barriers that individuals with limited 
English proficiency may face in improving financial literacy and 
conducting their financial affairs. These included two focus groups 
with individual consumers with limited English proficiency who speak 
Spanish and Vietnamese, respectively, and eight focus groups with 
service providers that included staff from community-based 
organizations, credit unions, credit counseling and financial 
education agencies, large banks, and community banks, all of which 
serve consumers with limited English proficiency. While the 
information we collected from our focus groups and from the 
organizations we contacted provided context on the issues discussed, 
it is not generalizable to the entire populations these groups 
represented. Further, our work may not have addressed all of the 
different perspectives of the many diverse cultures comprised by 
people with limited English proficiency in the United States. 

We conducted our work from August 2009 to May 2010 in accordance with 
all sections of GAO's Quality Assurance Framework that are relevant to 
our objective. The framework requires that we plan and perform the 
engagement to obtain sufficient and appropriate evidence to meet our 
stated objective and to discuss any limitations in our work. We 
believe that the information and data obtained, and the analysis 
conducted, provide a reasonable basis for any findings and conclusions 
in this product. 

Background: 

Financial literacy can be described as the ability to use knowledge 
and skills to manage money effectively. It includes the ability to 
understand financial choices, plan for the future, spend wisely, and 
manage the challenges that come with life events such as a job loss 
and saving for retirement or a child's education. It can also 
encompass financial education--the process by which people improve 
their understanding of financial products, services, and concepts. 
Financial literacy has received increased attention in recent years 
because poor financial management and decision making can result in a 
lower standard of living and prevent families from reaching important 
long-term goals, such as buying a home. Financial literacy has broader 
public policy implications as well. For example, the recent financial 
crisis can be attributed, at least in part, to unwise decisions by 
consumers about the use of credit. Moreover, educating the public 
about the importance of saving may be critical to boosting our 
national saving rate, an important element to improving America's 
economic growth. 

The population of adults with limited English proficiency in the 
United States is diverse with respect to immigration status, country 
of origin, educational background, literacy in native language, age, 
and family status. Generally, adults with limited English proficiency 
have immigrated to the United States and include legal permanent 
residents, naturalized citizens, refugees, and undocumented 
individuals, but some of these adults are native born. According to 
the Census Bureau's 2006-2008 American Community Survey, about 12.4 
million adults in the United States--or 5.5 percent of the total U.S. 
adult population--reported speaking English not well or not at all. 
[Footnote 2] As shown in table 1, our analysis of the Census data 
shows that Spanish was the native language of about 74 percent of 
those adults who did not speak English well or at all, with Chinese, 
Vietnamese, Korean, and Russian representing the next most common 
native languages. 

Table 1: Native Languages of U.S. Adults with Limited English 
Proficiency, 2006-2008: 

Language: Spanish; 
Adult limited English proficient population: 9,172,819; 
Percentage of adult limited English proficient population: 73.7%. 

Language: Chinese; 
Adult limited English proficient population: 676,308; 
Percentage of adult limited English proficient population: 5.4%. 

Language: Vietnamese; 
Adult limited English proficient population: 375,085; 
Percentage of adult limited English proficient population: 3.0%. 

Language: Korean; 
Adult limited English proficient population: 291,097; 
Percentage of adult limited English proficient population: 2.3%. 

Language: Russian; 
Adult limited English proficient population: 200,641; 
Percentage of adult limited English proficient population: 1.6%. 

Language: Portuguese; 
Adult limited English proficient population: 143,350; 
Percentage of adult limited English proficient population: 1.2%. 

Language: Polish; 
Adult limited English proficient population: 117,401; 
Percentage of adult limited English proficient population: 0.9%. 

Language: French Creole; 
Adult limited English proficient population: 114,042; 
Percentage of adult limited English proficient population: 0.9%. 

Language: Tagalog; 
Adult limited English proficient population: 94,105; 
Percentage of adult limited English proficient population: 0.8%. 

Language: Arabic; 
Adult limited English proficient population: 90,844; 
Percentage of adult limited English proficient population: 0.7%. 

Language: Other; 
Adult limited English proficient population: 1,171,366; 
Percentage of adult limited English proficient population: 9.4%. 

Language: Total; 
Adult limited English proficient population: 12,447,058; 
Percentage of adult limited English proficient population: 100.0%. 

Source: GAO analysis of 2006-2008 American Community Survey data. 

Note: "Limited English proficient" here refers to those who reported 
speaking English "not well" or "not at all." Numbers may not total due 
to rounding. 

[End of table] 

The number of American residents who reported speaking English not 
well or not at all grew by about 29 percent from the 2000 Census to 
the 2006-2008 American Community Survey data, as compared to those who 
reported speaking English very well or well, which grew by about 8 
percent during the same timeframe. As shown in figure 1, populations 
with limited English proficiency tend to be more concentrated in 
certain parts of the country. More than 13 percent of California's 
population was limited English proficient in 2008, as were more than 8 
percent of the populations of Texas, Arizona, and New York. 

Figure 1: Proportion of the Adult Population with Limited English 
Proficiency, 2006-2008: 

[Refer to PDF for image: illustrated map of the continental U.S.] 

The map depicts state and county borders and proportion of adults with 
limited English proficiency in the following categories: 

0 to less than 5 percent; 
5 percent to less than 10 percent; 
10 percent to less than 20 percent; 
20 percent or greater. 

Source: GAO analysis of 2006-2008 American Community Survey data; GAO 
(map). 

Note: "Limited English proficient" here refers to those who reported 
speaking English "not well" or "not at all." The geographic unit shown 
in the map is the Census Bureau's Public User Microdata Area. These 
areas are shaded according to the value of the estimated percentage of 
the population with limited English proficiency. The percentage 
estimates have 95 percent confidence intervals that are within plus or 
minus 4.5 percentage points of the estimate itself. However, if an 
estimate is 4 percent and the corresponding 95 percent confidence 
interval for that estimate is from 3.2 percent to 5.5 percent, the 
area is shaded "white" even though a portion of its confidence 
interval exceeds the 0-5 percent range. Refer to appendix I for 
additional information on the American Community Survey estimates and 
sampling error. 

[End of figure] 

Persons in the United States with limited English proficiency appear 
to have lower incomes, on average, than fluent English speakers. While 
limited data exist specifically on the relationship between limited 
English proficiency and economic status, an analysis of 2007 American 
Community Survey data by the Migration Policy Institute found that 20 
percent of those who spoke Spanish at home lived in poverty, as did 
11.8 percent of those who spoke Asian or Pacific Island languages, and 
21.1 percent of those who spoke other languages--as compared with a 
poverty rate of 11.2 percent among persons who spoke only English. 
[Footnote 3] A study by the Federal Reserve Bank of Chicago and the 
Brookings Institution, using 2004 data from the Congressional Budget 
Office, reported that the median income of a family headed by an 
immigrant (irrespective of English language proficiency) was $42,980--
and $34,798 for a family headed by an immigrant from Latin America--
compared with $54,686 for families headed by someone born in the 
United States.[Footnote 4] There are also indications that English 
proficiency correlates with educational attainment. For example, the 
Migration Policy Institute analysis found that 41 percent of adults in 
Spanish-speaking households in the United States did not finish high 
school, as compared with 12 percent of adults in English-only speaking 
households.[Footnote 5] 

Little prior research has been conducted specifically on the 
relationship between financial literacy and lack of proficiency in 
English. A 2005 research review by Lutheran Immigration and Refugee 
Service revealed almost no studies that examined how the immigrant 
experience influences financial literacy.[Footnote 6] Similarly, a 
literature search that we conducted found a significant amount of 
research on financial literacy in general and with regard to certain 
populations, but almost nothing that examined the role that language 
itself plays in financial literacy and financial education. Further, 
experts on financial literacy that we consulted in the nonprofit and 
federal sectors told us they were aware of little or no existing work 
specifically on the barriers to financial literacy faced by those with 
limited English proficiency. 

Some data do exist on financial literacy among Hispanic populations; 
however, the data do not generally distinguish between Hispanics who 
are and are not proficient in English.[Footnote 7] (About 70 percent 
of Hispanics in the United States self-report that they only speak 
English or they speak it well or very well, according to 2006-2008 
American Community Survey data.) Among the studies that did not 
directly address English language ability, a 2009 survey by the 
Financial Industry Regulatory Authority found that Hispanic 
respondents were less likely than Asian Americans and non-Hispanic 
Caucasians to answer basic financial literacy questions correctly. 
[Footnote 8] Further, a 2003 survey on retirement issues by the 
Employee Benefit Research Institute found that 43 percent of Hispanic 
workers described their personal knowledge as "knowing nothing" about 
investing or saving for retirement, as compared to 12 percent for all 
workers in the United States.[Footnote 9] The institute also found 
that those with the least amount of knowledge were much more likely to 
have poor English language skills. 

Language Barriers Can Impede Everyday Financial Transactions: 

Despite a lack of systematic research, a variety of stakeholders agree 
that a lack of proficiency in English can create significant barriers 
to financial literacy and to conducting everyday financial affairs, 
particularly given the complexity of financial products and the 
language often used to describe them. 

Limited English Proficiency Can Create Challenges to Conducting 
Financial Affairs: 

Staff we spoke with at financial institutions, federal agencies, and 
community and advocacy organizations that work with non-English 
speaking populations consistently told us that, in their experience, a 
lack of proficiency in English can be a significant barrier to 
financial literacy. Some explained that because language is the medium 
most used to access information and ideas, individuals lacking English 
language skills are limited in their ability to communicate with 
English-speaking financial service providers and to perform certain 
tasks necessary to initiate financial transactions and access 
financial tools and educational materials. For example: 

* Completing key documents. Service providers and consumers with 
limited English proficiency told us that most financial documents are 
available only in English, which limits the ability of individuals 
with limited English proficiency to complete applications, understand 
and sign contracts, and conduct other everyday financial affairs 
without assistance. Several representatives from financial 
institutions told us that they are reluctant to provide translations 
of documents, such as disclosures and contracts, because of liability 
concerns. 

* Managing bank accounts. Several bankers and others with whom we 
spoke noted that individuals who can not write in English find it 
difficult to write checks, which requires spelling out a dollar 
amount. For this reason, they said, debit card use has become popular 
among some individuals with limited English proficiency. The financial 
literacy study by Lutheran Immigration and Refugee Service noted that 
some refugees with limited literacy skills have difficulty using banks 
because they are not able to track deposits and withdrawals from their 
accounts.[Footnote 10] 

* Resolving problems. Some consumers and service providers we spoke 
with said that limited English proficiency serves as a particular 
barrier when it comes to asking questions, such as inquiring about 
additional fees on credit card statements, or resolving problems, such 
as correcting erroneous billing statements. One consumer with limited 
English proficiency told us that although he speaks some English, he 
has difficulty understanding and negotiating automated telephone menu 
systems that one must often use to get assistance. 

* Accessing financial education. Although there is a multitude of 
print material, Web sites, broadcast media, and classroom curricula 
provided by government, nonprofit, and private sources aimed at 
improving financial education, these resources are not always 
available in languages other than English. Financial education 
initiatives that are provided in languages other than English or that 
are aimed at particular immigrant populations do exist (see appendix 
II), but are more limited, especially for speakers of languages other 
than Spanish. 

Financial Products Often Use Language That Is Particularly Complex: 

Information and documents related to financial products tend to be 
very complex and can be hard to understand, even for native English 
speakers. The Financial Literacy and Education Commission, which is 
comprised of 20 federal agencies, has noted that personal financial 
management is an extremely complex matter that requires significant 
resources and commitment for consumers to understand and evaluate the 
multitude of financial products available in the marketplace.[Footnote 
11] Moreover, the language used in financial documents can be 
extremely confusing. For instance, in 2006 we reported that credit 
card disclosures were often written well above the eighth-grade level 
at which about half of U.S. adults read.[Footnote 12] In a separate 
report, we similarly found that the disclosures made by various 
lenders to inform consumers of the risks of alternative mortgage 
products, such as interest-only loans, used language too complex for 
many adults to understand.[Footnote 13] A study by the Federal Trade 
Commission in 2007 on consumer mortgage disclosures reported that home 
loan borrowers were frequently confused by the disclosures about their 
mortgages and experienced significant misunderstandings about the 
terms of their loans.[Footnote 14] 

Having limited proficiency in English clearly exacerbates these 
challenges. In 2008, the National Council of La Raza sponsored four 
focus groups on credit issues and found that, for some Hispanics, 
language barriers compounded the difficulties that all participants 
faced in understanding the jargon and fine print of applications, 
contracts, and credit reports.[Footnote 15] The report by Lutheran 
Immigration and Refugee Service stated that advanced literacy skills 
are needed to understand the terms and conditions tied to most 
financial contracts and that it can take up to 5 years of regular 
English communication and practice for an immigrant who is not a 
native English speaker to achieve that level of advanced literacy. 
[Footnote 16] These findings were corroborated through focus groups we 
conducted with a wide range of individuals who provide financial and 
social services to populations who lack English proficiency. These 
providers frequently noted that the complexity and specialized 
language of financial services can make conducting financial affairs 
particularly challenging for individuals with limited English 
proficiency. 

Translation of Financial Information May Not Always Be Effective: 

In some cases, written financial materials are provided in languages 
other than English, but the translation may not be fully 
comprehensible if it is not written using colloquial or culturally 
appropriate language. A 2004 report by the National Council of La Raza 
noted that financial education materials are often translated from 
English to their literal equivalent in Spanish, which may be 
unintelligible or difficult for the reader to understand.[Footnote 17] 
The report recommended the use of translation that attempts to convey 
images or messages without regard to literal phrasing and that would 
account for cultural differences and capture and clarify the meaning 
of terms. Financial service providers we spoke with also noted that 
many specific terms used in the U.S. financial system--such as 
"subprime" and "401K"--do not always have equivalent terms in other 
languages, which can make translation particularly difficult. Some 
financial education materials for those with limited English 
proficiency provide English and translated versions side-by-side to 
help readers improve their financial vocabulary and recognize key 
terms. 

Interpretation--that is, oral translation--can also be problematic. 
The service providers we spoke with said that individuals with limited 
English proficiency frequently rely on friends and family members to 
serve as interpreters when dealing with financial affairs. However, 
interpreters may not be reliable because they may not fully understand 
or be able to explain the material. In particular, advocates for 
immigrant communities told us that adults often use as interpreters 
their minor children, who may not have the ability to accurately 
convey complex information. The Lutheran Immigration and Refugee 
Service report noted that many immigrants rely on relatives already 
residing in the United States to introduce them to the American 
financial system even though their family members may not have 
complete or accurate information themselves.[Footnote 18] In focus 
groups conducted for a report by Freddie Mac on Asian homebuyers, 
Chinese, Korean, and Vietnamese immigrants said that one of the key 
reasons they would rather use Asian real estate agents is because they 
preferred to conduct business in their native language, even when they 
were proficient in English.[Footnote 19] 

Some financial institutions have staff that can interpret or provide 
information in languages other than English, but it is unclear how 
widely this occurs. A report by the public interest group Appleseed on 
expanding and improving services for immigrants noted that the absence 
of culturally competent bilingual staff and services is a barrier to 
providing financial services to the low-and moderate-income immigrant 
market.[Footnote 20] In the same way, the financial education report 
by the National Council of La Raza stated that U.S. banks do not 
always employ bicultural, bilingual staff who can meet the diverse 
needs of Hispanics, especially immigrants.[Footnote 21] One provider 
told us that providing bilingual customer service can be challenging 
because even bilingual employees may not be able to accurately explain 
all the financial products offered by the institution. The 
representative of one financial services firm told us it forbids its 
staff from translating information or serving as interpreters for fear 
of providing incorrect or incomplete information. Similarly, an 
article in the trade journal Employee Benefit News cautioned that 
asking bilingual employees to present benefits information can be 
risky because the employee may lack financial expertise and the 
knowledge to explain industry-specific terms.[Footnote 22] 

Many Factors Other Than Language Influence the Financial Literacy of 
Individuals with Limited English Proficiency: 

Federal agency officials as well as financial literacy experts and 
staff from service providers such as nonprofit organizations, credit 
unions, and banks that work with immigrant communities informed us 
that factors other than language often serve as barriers to financial 
literacy for people with limited English proficiency. These factors 
can include a lack of familiarity with the U.S. financial system, 
cultural differences, general mistrust of financial institutions, and 
income and education levels. 

* Lack of familiarity with the U.S. financial system. Some immigrants 
to the United States--some of whom are not proficient in English--lack 
familiarity with the U.S. financial system and its products, which may 
differ greatly from those in their native countries. These individuals 
may not have had exposure to mainstream financial institutions, such 
as banks, or may not have had experience with credit cards or 
retirement programs. A 2006 study sponsored by the Inter-American 
Development Bank noted that many new Hispanic immigrants have never 
had a bank account and that this is one of the obstacles that stand in 
the way of greater financial integration of recent Hispanic 
immigrants.[Footnote 23] Similarly, in focus groups conducted by 
Freddie Mac for its report on Asian homebuyers, new Asian immigrants 
cited unfamiliarity with the U.S. financial system as one challenge 
that they faced.[Footnote 24] Officials at the Internal Revenue 
Service told us that individuals with limited English proficiency 
often face additional challenges understanding the U.S. tax system, in 
part because the tax system in their home country was very different. 
Further, in the report by Lutheran Immigration and Refugee Service, 
service providers noted that new immigrants with limited banking 
experience were generally unclear about what happens to money they 
deposit and how they can access these funds; many are also new to the 
very concept of a credit system.[Footnote 25] Additionally, one 
service provider told us that many new immigrants do not have their 
parents' or previous generations' financial experiences and lessons in 
the United States to learn from. 

* The role of culture. Cultural differences can play a role in 
financial literacy and the conduct of financial affairs because 
different populations have dissimilar norms, attitudes, and 
experiences related to managing money. For example, in some cultures 
the practice of borrowing money and carrying debt is viewed 
negatively, which may deter immigrants from such cultures from taking 
loans to purchase homes or cars and build credit histories. In focus 
groups of Asian homebuyers conducted by Freddie Mac, most participants 
expressed an aversion to debt, and some participants said they were 
accustomed to spending cash rather than using credit cards because 
they do not like to be in debt.[Footnote 26] Religious traditions can 
also influence the use of credit. The Lutheran Immigration and Refugee 
Service report notes that Muslims who adhere to religious prohibitions 
against receiving and paying interest face challenges participating in 
such mainstream financial products as home mortgages and retirement 
plans.[Footnote 27] 

* Mistrust of financial institutions. Some immigrants' attitudes 
toward financial institutions have been shaped by their observations 
and experiences in their home countries. One academic paper on 
immigrants' access to financial services noted that some U.S. 
immigrant households do not have bank accounts because of mistrust of 
banks, particularly if financial institutions in their home countries 
were marked by instability, lack of transparency, or fraud.[Footnote 
28] A study sponsored by the Inter-American Development Bank similarly 
noted that negative attitudes towards depository financial 
institutions or a desire to keep financial information private has 
been an obstacle to using banks among some Hispanic immigrants. 
[Footnote 29] 

* Income and socioeconomic status. Some studies have reported a 
correlation between income and financial literacy. As noted earlier, 
individuals with limited English proficiency have lower incomes, on 
average, than the U.S. population as a whole. In a 2008 survey of 
young American adults for the Jump$tart Coalition for Personal 
Financial Literacy, respondents whose family income was less than 
$20,000 per year received an average score of about 43 percent on a 
test of personal finance basics, as compared to a score of about 52 
percent for students whose parents' income was more than $80,000. 
[Footnote 30] A few financial service providers to immigrant 
communities we spoke with noted that low-income individuals may not 
have access to tools, such as educational courses and Internet sites, 
to improve their money management skills and overall financial 
literacy. The financial education report by the National Council of La 
Raza stated that the many Hispanic low-wage earners with work schedule 
restrictions or multiple jobs were limited in the ways in which they 
could participate in financial education programs.[Footnote 31] 

* Education. As noted earlier, there is evidence that people in the 
United States with limited English proficiency are more likely to have 
low educational attainment. Moreover, overall levels of education can 
affect financial literacy. For example, the Jump$tart Coalition survey 
found a correlation between test scores on the basics of financial 
literacy and the educational attainment of test takers and their 
parents.[Footnote 32] Similarly, researchers with the Board of 
Governors of the Federal Reserve System who reviewed consumer survey 
data from the University of Michigan found a statistically significant 
correlation between respondents' levels of formal education and their 
ability to correctly answer a series of true-false questions 
concerning savings, credit, and other general financial management 
matters.[Footnote 33] Staff at organizations that serve or advocate 
for immigrants told us that one factor in the ability to conduct 
financial affairs effectively is basic literacy--that is, the ability 
to read or write even in one's native language. People with limited 
English proficiency who are not literate in any language face clear 
barriers to learning about and understanding financial issues, which 
can greatly impede their ability to conduct their everyday financial 
affairs. 

Some service providers and advocates told us that because factors 
other than language affect the financial literacy of people with 
limited English proficiency, translations of financial products and 
financial education materials may not be sufficient to address 
obstacles to financial literacy. While overcoming language barriers is 
important, they said, efforts to improve the financial literacy and 
well-being of people with limited English proficiency must also 
address underlying cultural and socioeconomic issues. 

Consumers with Limited English Proficiency Are More Likely to Use 
Alternative Financial Services and May Be More Susceptible to 
Fraudulent and Predatory Practices: 

Evidence suggests that people with limited English proficiency are 
more likely than the U.S. population as a whole not to have accounts 
at banks and other mainstream financial institutions. This condition 
is commonly referred to as being "unbanked" or "underbanked."[Footnote 
34] A 2009 national survey by the Federal Deposit Insurance 
Corporation (FDIC) found that 35.6 percent of households where only 
Spanish was spoken at home were unbanked, compared with 7.1 percent of 
households in which Spanish was not the only language spoken at home. 
[Footnote 35] Similarly, another study on the use of financial 
services by Hispanic immigrants found that they were significantly 
more likely to be unbanked than nonimmigrants, although it did not 
report specifically on the role of language.[Footnote 36] The FDIC 
survey found that among households who had never had a bank account, 
9.1 and 6.9 percent cited that it was because "banks do not feel 
comfortable or welcoming" and "there are language barriers at banks," 
respectively.[Footnote 37] Further, as noted earlier, immigrants may 
come from countries with corrupt or insecure financial systems, which 
can diminish their trust in mainstream financial institutions in the 
United States. In addition, persons with limited English proficiency 
who are undocumented may be further deterred from opening a bank 
account because of fear that the institution will share personal 
information with immigration authorities, according to the Lutheran 
Immigration and Refugee Service study and a few service providers we 
spoke with.[Footnote 38] According to FDIC, unbanked or underbanked 
consumers may pay excessive fees for basic financial services, be more 
vulnerable to loss or theft, and struggle to build credit histories 
and achieve financial security.[Footnote 39] 

FDIC has also reported that households that are unbanked are more 
likely to use alternative financial services, and about two-thirds of 
these households used pawn shops, payday loans, rent-to-own 
agreements, nonbank money orders, or check-cashing services in the 
past year.[Footnote 40] There are a number of reasons why populations 
with limited English proficiency may be more likely to use alternative 
financial services. First, alternative financial service providers, 
such as payday lenders and check-cashing outlets, generally cluster in 
and around neighborhoods with lower-income, minority, and Hispanic 
families, according to a 2004 analysis by the Urban Institute. 
[Footnote 41] The Lutheran Immigration and Refugee Service study said 
that in each of the five cities researchers visited, alternative 
financial services appeared to be widely available in neighborhoods 
where new immigrants lived, noting that immigrants were often 
aggressively targeted for these services through direct mail, 
telemarketing, and door-to-door sales.[Footnote 42] Some immigrants 
are attracted to alternative financial service providers because these 
institutions often cater specifically to their communities by, among 
other things, requiring little or no documentation, hiring staff who 
speak the language of their community, and offering convenient hours. 
However, concerns exist about the widespread use of such alternative 
financial service providers since the loan fees they charge are 
generally much higher than those charged by traditional financial 
institutions, and other terms and conditions of such loans are often 
unfavorable to the borrower. 

Further, evidence suggests that some populations with limited English 
language skills may be more susceptible to fraudulent and predatory 
practices. The Lutheran Immigration and Refugee Service report noted 
that some immigrants may trust financial service providers who speak 
their native language even if they do not understand the legalities of 
agreements they make.[Footnote 43] Service providers that work with 
limited English proficient communities told us that in some cases 
unscrupulous individuals use their ability to converse fluently in 
someone's native language to build trust and then take advantage of 
the person. Some service providers described to us scams they have 
observed in which individuals with limited English skills are told the 
terms of an agreement orally in their native language and then asked 
to sign a written contract in English with terms different than those 
described. Credit counselors we spoke with said that having limited 
proficiency in English can make it difficult to understand the 
distinctions between various financial products. The report by the 
Appleseed organization notes that language and cultural barriers may 
also make it harder for immigrants, including those with limited 
English skills, to register a complaint about an abusive practice or 
product.[Footnote 44] 

The Federal Trade Commission has similarly noted that Hispanic 
immigrants, especially those with limited English proficiency, may be 
more susceptible to consumer fraud such as credit card fraud and other 
abusive practices. According to the agency, it pursued 37 cases 
involving Spanish-language frauds targeted at Hispanic consumers as 
part of its Hispanic Law Enforcement and Outreach Initiative between 
April 2004 and September 2006.[Footnote 45] The Federal Trade 
Commission has also translated dozens of its consumer education 
publications into Spanish, in part to reduce the susceptibility of 
Spanish-speaking consumers to fraud and scams. Several service 
providers we spoke with said that financial education can play an 
important role in helping consumers with limited English proficiency 
avoid abusive and predatory practices. 

Agency Comments: 

We provided a draft of this report to the Department of the Treasury 
and the Federal Trade Commission for their review and neither agency 
had any comments. 

We are sending copies of this report to the Secretary of the Treasury, 
the Chairman of the Federal Trade Commission, and interested 
congressional committees. In addition, the report will be available at 
no charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-8678 or cackleya@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III. 

Signed by: 

Alicia Puente Cackley: 
Director, Financial Markets and Community Investment: 

[End of section] 

Appendix I: Scope and Methodology: 

Our reporting objective was to examine the extent, if any, to which 
individuals with limited English proficiency are impeded in their 
financial literacy and conduct of financial affairs. To address this 
objective, we conducted a review of relevant literature related to 
financial literacy among immigrants and people with limited English 
proficiency. To identify existing studies, reports, articles, and 
surveys, we conducted searches of several databases, including 
Business & Industry, Banking Info Source, and EconLit, using key words 
to link financial literacy or financial education to language, English 
proficiency, and other concepts. We also asked for recommendations for 
studies, reports, and articles from academic experts and from 
representatives of organizations that address issues related to 
financial literacy or limited English proficient communities. We also 
conducted focused Internet searches, and we reviewed the 
bibliographies of reports we had already obtained to identify 
additional material. Each of the documentary sources cited in our 
report was reviewed for methodological strength and reliability and 
determined to be sufficiently reliable for our purposes. We performed 
our searches from August 2009 to April 2010. 

To describe the U.S. population of individuals with limited English 
proficiency, we obtained and analyzed data from the United States 
Census Bureau's 2006-2008 American Community Survey and the 2000 U.S. 
Census.[Footnote 46] The Census Bureau does not define the term 
"limited English proficient." As such, we developed our measures of 
the limited English proficient population based on questions in the 
American Community Survey that asked "Does this person speak a 
language other than English at home?", "What is the language?", and 
"How well does this person speak English?" For our purposes, we 
included in the limited English proficient estimate individuals over 
the age of 18 who self-reported that they speak English "not well" or 
"not at all". We determined the total number of limited English 
proficient individuals as compared to the population that is 
proficient in English (those who reported they speak English "very 
well" or "well") for both the 2006-2008 American Community Survey data 
and the 2000 U.S. Census data to show the growth over a period of 
time. Because the American Community Survey data is a probability 
sample based on random selections, this sample is only one of a large 
number of samples that might have been selected. Since each sample 
could have provided different estimates, we express our confidence in 
the precision of our particular sample's results as a 95 percent 
confidence interval (e.g., plus or minus 4.5 percentage points). This 
is the interval that would contain the actual population value for 95 
percent of the samples that could have been drawn. In this report, all 
Public User Microdata Area level percentage estimates derived from the 
2006-2008 American Community Survey have 95 percent confidence levels 
of plus or minus 4.5 percentage points or less, unless otherwise noted. 

We also conducted interviews at and gathered relevant studies and 
educational materials from federal agencies, organizations that 
provide financial literacy and education, and organizations that serve 
or advocate for populations with limited English proficiency. We 
interviewed staff at the Department of the Treasury's Office of 
Financial Education, Federal Trade Commission, Internal Revenue 
Service, Federal Deposit Insurance Corporation, and the Department of 
Health and Human Services' Office of Refugee Resettlement. We also 
interviewed representatives and gathered documentation from 
organizations that address financial literacy issues, including 
Consumer Action, Consumer Federation of America, and the Jump$tart 
Coalition for Personal Financial Literacy; organizations that 
represent the interests of populations that include individuals with 
limited English proficiency, including the Asian American Justice 
Center, National Coalition for Asian Pacific American Community 
Development, National Council of La Raza, and Southeast Asia Resource 
Action Center; and organizations that represent financial service 
providers, including the American Bankers Association, Credit Union 
National Association, and National Foundation for Credit Counseling. 
We also gathered information from three academic researchers who focus 
on issues related to financial literacy or limited English proficiency. 

In addition, we conducted a series of 10 focus groups to discuss the 
barriers that individuals with limited English proficiency may face in 
improving financial literacy and conducting their financial affairs. 
Information we collected from our focus groups and from the 
organizations we contacted provided context on the issues discussed, 
but this information is not generalizable to the entire populations 
represented by the focus groups. Further, our work may not have 
addressed all of the different perspectives of the many diverse 
cultures comprised by people with limited English proficiency in the 
United States. For each focus group, we used a series of semi- 
structured questions to learn about participants' observations and 
experiences related to language and other barriers that impede 
financial literacy and how they address these challenges. The focus 
groups included: 

* 1 with 11 limited English proficient consumers whose native language 
was Spanish and who were enrolled in English-language classes 
sponsored by the Hispanic Committee of Virginia; 

* 1 with 11 limited English proficient consumers whose native language 
was Vietnamese and who utilize the services of Boat People SOS, a 
community-based organization based in the Washington, D.C. area; 

* 4 that collectively included 20 staff members representing 15 
financial institutions--large banks, community banks, and credit 
unions across the country whose clients include a large number of 
limited English proficient individuals with a wide range of native 
languages; 

* 1 with 10 staff members representing 5 credit counseling and 
financial education agencies that provide services in multiple 
languages; 

* 2 that collectively included 19 staff members representing 16 
nonprofit community-based organizations that largely serve Hispanic 
communities; and: 

* 1 with 9 staff members representing 8 nonprofit community-based 
organizations that largely serve a variety of Asian communities. 

We conducted our work from August 2009 to May 2010 in accordance with 
all sections of GAO's Quality Assurance Framework that are relevant to 
our objective. The framework requires that we plan and perform the 
engagement to obtain sufficient and appropriate evidence to meet our 
stated objective and to discuss any limitations in our work. We 
believe that the information and data obtained, and the analysis 
conducted, provide a reasonable basis for any findings and conclusions 
in this product. 

[End of section] 

Appendix II: Examples of Financial Education Targeted at Populations 
with Limited English Proficiency: 

Many entities--including federal agencies, state and local 
governments, financial institutions and other private sector entities, 
schools, community-based agencies, and other nonprofit organizations--
sponsor financial literacy and education initiatives. These efforts 
cover a wide variety of topics, target a range of audiences, and 
include classroom curricula, print materials, Web sites, broadcast 
media, and individual counseling. Highlighted below are selected 
examples of initiatives taken in the federal, nonprofit, and private 
sectors that seek to reach, in particular, individuals with limited 
English proficiency. 

Federal Agencies: 

About 20 different federal agencies operate numerous financial 
literacy programs and initiatives, several of which are targeted in 
part or whole at individuals with limited proficiency in English. 
[Footnote 47] The federal government's multiagency Financial Literacy 
and Education Commission sponsors the My Money Web site 
(www.MyMoney.gov), which serves as a portal to more than 260 other 
federal financial education sites. The site has both English-and 
Spanish-language versions. The commission also sponsors a financial 
literacy telephone hotline that supports both English-and Spanish-
speaking callers, as well as a financial literacy "tool kit" of 
publications available in English and Spanish. One of the most widely 
used federal financial literacy programs is the Federal Deposit 
Insurance Corporation's "Money Smart," a financial education 
curriculum designed to help individuals who are outside the financial 
mainstream develop financial skills and positive banking 
relationships. The instructor-led curriculum is offered in English, 
Spanish, Chinese, Hmong, Korean, Vietnamese and Russian, while the 
computer-based curriculum is available in English and Spanish. The 
Federal Trade Commission has developed more than 150 culturally 
appropriate educational publications in Spanish, according to an 
agency official, many of which cover financial topics, and its Spanish-
language Web site received more than 1 million hits in fiscal year 
2009. The Federal Trade Commission has also created Spanish-language 
videos on such topics as avoiding foreclosure rescue scams, and agency 
staff have provided interviews on financial issues to local and 
national Spanish-language media. 

Nonprofit Sector: 

A variety of community-based and national nonprofit organizations 
throughout the nation have financial literacy initiatives aimed at 
populations with limited proficiency in English. Many housing 
counseling agencies approved by the Department of Housing and Urban 
Development offer services in multiple languages. For example, the 
Minnesota Home Ownership Center has interpreters trained in 
homeownership issues and financial terminology and offers homebuyer- 
education classes in Spanish, Cambodian, Russian, and Hmong. Some 
community-based organizations also provide financial literacy 
information through their English as a Second Language programs, using 
resources such as the Money Smart curriculum, which includes such 
topics as the U.S. credit system and credit scores, and purchasing a 
home. Some agencies offer individual counseling. For example, two 
large nationwide providers of credit counseling and financial 
education can conduct telephone sessions in at least 15 languages 
directly and about 150 languages using a translation-services 
contractor. Many nonprofit agencies offer written publications in 
multiple languages intended to improve consumer financial literacy. 
For example, the National Coalition for Asian Pacific American 
Community Development publishes financial literacy resources in 
Chinese, Korean, Vietnamese, Hindi, Urdu, and Samoan. Similarly, 
Consumer Action posts to its Web site consumer financial information 
in several languages. 

Private Sector: 

Several financial institutions and other private sector entities have 
sponsored financial literacy initiatives aimed at consumers who speak 
languages other than English. For example, Freddie Mac's CreditSmart®--
a financial education curriculum designed to help consumers build and 
maintain better credit and become homeowners--is available in Spanish 
through CreditSmart Español and in Chinese, Korean, and Vietnamese 
through CreditSmart Asian. The American Bankers Association provides a 
newsletter in Spanish called Money Talks that is tailored to varying 
age groups and offers personal finance booklets in Spanish on such 
topics as saving, credit, budgeting, checking accounts, and mortgages. 
The Credit Union National Association offers "El Poder es Tuyo," a 
Spanish-language personal-finance Web site that provides culturally 
relevant articles, videos, and worksheets specifically designed for 
Hispanics. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Alicia Puente Cackley, (202) 512-8678 or cackleya@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Jason Bromberg (Assistant 
Director), Grant Mallie, Linda Rego, Rhonda Rose, Jennifer Schwartz, 
Andrew Stavisky, and Betsey Ward made key contributions to this report. 

[End of section] 

Related GAO Products: 

Reports Related to Financial Literacy: 

Financial Literacy and Education Commission: Progress Made in 
Fostering Partnerships, but National Strategy Remains Largely 
Descriptive Rather Than Strategic. [hyperlink, 
http://www.gao.gov/products/GAO-09-638T]. Washington, D.C.: April 29, 
2009. 

Financial Literacy and Education Commission: Further Progress Needed 
to Ensure an Effective National Strategy. [hyperlink, 
http://www.gao.gov/products/GAO-07-100]. Washington, D.C.: December 4, 
2006. 

Credit Reporting Literacy: Consumers Understood the Basics but Could 
Benefit from Targeted Educational Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-05-223]. Washington, D.C.: March 16, 
2005. 

Highlights of a GAO Forum: The Federal Government's Role in Improving 
Financial Literacy. [hyperlink, 
http://www.gao.gov/products/GAO-05-93SP]. Washington, D.C.: November 
15, 2004. 

Reports Related to Limited English Proficiency: 

Centers for Medicare and Medicaid Services: CMS Should Develop an 
Agencywide Policy for Translating Medicare Documents Into Languages 
Other Than English. [hyperlink, 
http://www.gao.gov/products/GAO-09-752R]. Washington, D.C.: July 30, 
2009. 

Medicare: Callers Can Access 1-800-MEDICARE Services, but 
Responsibility within CMS for Limited English Proficiency Plan 
Unclear. [hyperlink, http://www.gao.gov/products/GAO-09-104]. 
Washington, D.C.: December 29, 2008. 

VA Health Care: Facilities Have Taken Action to Provide Language 
Access Services and Culturally Appropriate Care to a Diverse Veteran 
Population. [hyperlink, http://www.gao.gov/products/GAO-08-535]. 
Washington, D.C.: May 28, 2008. 

No Child Left Behind Act: Education's Data Improvement Efforts Could 
Strengthen the Basis for Distributing Title III Funds. [hyperlink, 
http://www.gao.gov/products/GAO-07-140]. Washington, D.C.: December 7, 
2006. 

No Child Left Behind: Education Assistance Could Help States Better 
Measure Progress of Students with Limited English Proficiency. 
[hyperlink, http://www.gao.gov/products/GAO-07-646T]. Washington, 
D.C.: March 23, 2007. 

Child Care and Early Childhood Education: More Information Sharing and 
Program Review by HHS Could Enhance Access for Families with Limited 
English Proficiency. [hyperlink, 
http://www.gao.gov/products/GAO-06-807]. Washington, D.C.: August 17, 
2006 (Spanish Summary: [hyperlink, 
http://www.gao.gov/products/GAO-06-949]; Chinese Summary: GAO-06-950; 
Korean Summary: GAO-06-951; Vietnamese Summary: [hyperlink, 
http://www.gao.gov/products/GAO-06-952]). 

No Child Left Behind Act: Assistance from Education Could Help States 
Better Measure Progress of Students with Limited English Proficiency. 
[hyperlink, http://www.gao.gov/products/GAO-06-815]. Washington, D.C.: 
July 26, 2006. 

Transportation Services: Better Dissemination and Oversight of DOT's 
Guidance Could Lead to Improved Access for Limited English-Proficient 
Populations. [hyperlink, http://www.gao.gov/products/GAO-06-52]. 
Washington, D.C.: November 2, 2005 (Spanish Summary: [hyperlink, 
http://www.gao.gov/products/GAO-06-185]; Chinese Summary: [hyperlink, 
http://www.gao.gov/products/GAO-06-186]; Vietnamese Summary: 
[hyperlink, http://www.gao.gov/products/GAO-06-187]; Korean Summary: 
[hyperlink, http://www.gao.gov/products/GAO-06-188]). 

[End of section] 

Footnotes: 

[1] Pub. L. No. 111-24, § 513, 123 Stat. 1734, 1765-66 (2009). 

[2] In the Census Bureau data, English speaking ability is self- 
reported by adults ages 18 and over who have indicated that they speak 
a language other than English at home. The survey, which is provided 
in multiple languages, allows respondents to choose between speaking 
English "very well," "well," "not well," or "not at all." For the 
purposes of this report, we included in our calculations of the adult 
limited English proficient population those who reported speaking 
English either "not well" or "not at all," but other sources may use 
different definitions for limited English proficiency. 

[3] Migration Policy Institute, "United States Fact Sheet on Income 
and Poverty" (2007), [hyperlink, 
http://www.migrationinformation.org/datahub/state4.cfm?ID=US] 
(accessed Feb. 23, 2010). 

[4] Federal Reserve Bank of Chicago and the Brookings Institution, 
"Financial Access for Immigrants: Lessons from Diverse Perspectives" 
(May 2006), [hyperlink, 
http://www.chicagofed.org/digital_assets/others/communities/financial_ac
cess_for_immigrants/lessons_from_diverse_perspectives.pdf] (accessed 
Mar. 29, 2010). 

[5] Migration Policy Institute, "United States Fact Sheet on Language 
and Education" (2007), [hyperlink, 
http://www.migrationinformation.org/datahub/state2.cfm?ID=US] 
(accessed Feb. 23, 2010). 

[6] Lutheran Immigration and Refugee Service, "Financial Literacy for 
Newcomers: Weaving Immigrant Needs into Financial Education" 
(Baltimore, Maryland: Mar. 27, 2006), [hyperlink, 
http://www.refugeeworks.org/downloads/rw_financial_literacy.pdf] 
(accessed Aug. 12, 2009). 

[7] The terms "Hispanic" and "Latino" are used interchangeably by the 
Census Bureau to identify persons of Mexican, Puerto Rican, Cuban, 
Central and South American, Dominican, and Spanish descent. Throughout 
this report, we consistently refer to these individuals as Hispanic. 

[8] Applied Research and Consulting, LLC for Financial Industry 
Regulatory Authority Investor Education Foundation, "Financial 
Capability in the United States: Initial Report of Research Findings 
from the 2009 National Survey" (New York, New York: Dec. 1, 2009), p. 
41, [hyperlink, 
http://www.finrafoundation.org/resources/research/p120478] (accessed 
Dec. 15, 2009). 

[9] Employee Benefit Research Institute, American Savings Education 
Council, and Matthew Greenwald and Associates, Inc., "The 2003 
Retirement Confidence Survey Summary of Findings" (2003), [hyperlink, 
http://www.ebri.org/pdf/surveys/rcs/2003/03rcssof.pdf] (accessed Mar. 
12, 2010). 

[10] Lutheran Immigration and Refugee Service, p. 11. 

[11] Financial Literacy and Education Commission, Taking Ownership of 
the Future: The National Strategy for Financial Literacy (Washington, 
D.C.: April 2006), p. vii. 

[12] GAO, Credit Cards: Increased Complexity in Rates and Fees 
Heightens Need for More Effective Disclosures to Consumers, 
[hyperlink, http://www.gao.gov/products/GAO-06-929] (Washington, D.C.: 
Sept. 12, 2006). 

[13] GAO, Alternative Mortgage Products: Impact on Defaults Remains 
Unclear, but Disclosure of Risks to Borrowers Could Be Improved, 
[hyperlink, http://www.gao.gov/products/GAO-06-1021] (Washington, 
D.C.: Sept. 19, 2006). 

[14] Federal Trade Commission, Bureau of Economics Staff Report, James 
M. Lacko and Janis K. Pappalardo, "Improving Consumer Mortgage 
Disclosures: An Empirical Assessment of Current and Prototype 
Disclosure Forms" (June 2007), [hyperlink, 
http://www.ftc.gov/os/2007/06/P025505MortgageDisclosureReport.pdf] 
(accessed Mar. 31, 2010). 

[15] Greenberg Quinlan Rosner Research for National Council of La 
Raza, NCLR: Credit Education Materials Development Focus Group Report 
(July 25, 2008), p. 1. 

[16] Lutheran Immigration and Refugee Service, pp. 10-11. 

[17] Muñiz, Brenda, "Financial Education in Latino Communities: An 
Analysis of Programs, Products, and Results/Effects," National Council 
of La Raza (Washington, D.C.: 2004), p. 11, [hyperlink, 
http://www.nclr.org/content/publications/detail/28618/] (accessed Aug. 
12, 2009). 

[18] Lutheran Immigration and Refugee Service, p. 15. 

[19] Freddie Mac, "Homeward Bound: An In-depth Look at Asian 
Homebuyers in the United States" (McLean, Virginia: December 2005), p. 
19, [hyperlink, 
http://www.freddiemac.com/news/pdf/Asian_Homebuyers_in_the_US.pdf]  
(accessed Nov. 4, 2009). 

[20] Appleseed, "Expanding and Improving Financial Services for Low-
and Moderate-Income Immigrant Communities: Next Steps" (Washington, 
D.C.: 2006), p. 4, [hyperlink, 
www.texasappleseed.net/pdf/report_financial_ExpandImprove_2006.pdf] 
(accessed Mar. 10, 2010). 

[21] Muñiz, National Council of La Raza, p.11. 

[22] Melissa Burkhart and Ferney Colorado, "Encouraging Spanish- 
speakers' participation in retirement plans," Employee Benefit News 
(July 1, 2007), [hyperlink, 
http://ebn.benefitnews.com/news/encouraging-spanish-speakers-
participation-retirement-plans-106968-1.html] (accessed Sept. 2, 2009). 

[23] Sarah Stookey, PhD, sponsored by the Inter-American Development 
Bank/Multilateral Investment Fund, Financial Services Segregation: 
Improving Access to Financial Services for Recent Latino Immigrants 
(July 2006), p. 21. 

[24] Freddie Mac, Homeward Bound, p. 8. 

[25] Lutheran Immigration and Refugee Service, p. 8. 

[26] Freddie Mac, Homeward Bound, pp. 4 and 11. 

[27] Lutheran Immigration and Refugee Service, p. 10. A small but 
growing number of financial entities, nonprofits, and for-profit 
wholesalers in the United States offer financial products designed to 
comply with Islamic law, as well as with state and federal 
regulations. See Chicago Fed Letter, Islamic finance in the United 
States: A small but growing industry (Chicago: May 2005). 

[28] Una Okonkwo Osili and Anna L. Paulson, "Immigrants' Access to 
Financial Services and Asset Accumulation," Insufficient Funds: 
Savings, Assets, Credit and Banking Among Low-Income Households (New 
York, New York: Russell Sage Foundation Press, 2009). 

[29] Stookey, Inter-American Development Bank, p. 21. 

[30] Lewis Mandell, PhD, for the Jump$tart Coalition for Personal 
Financial Literacy, The Financial Literacy of Young American Adults: 
Results of the 2008 National Jump$tart Coalition Survey of High School 
Seniors and College Students (Washington, D.C.: 2008), p. 12. 

[31] Muñiz, National Council of La Raza, p.11. 

[32] Lewis Mandell, PhD, The Financial Literacy of Young American 
Adults, p. 13. 

[33] Sandra Braunstein and Carolyn Welch, "Financial Literacy: An 
Overview of Practice, Research, and Policy," Federal Reserve Bulletin 
(November 2002), p. 455, [hyperlink, 
http://www.federalreserve.gov/pubs/bulletin/2002/1102lead.pdf] 
(accessed Apr. 5, 2010). The article reported, among other things, on 
the Survey of Consumers, a monthly telephone survey of a sample of 
U.S. households conducted by the University of Michigan Survey 
Research Center. 

[34] FDIC has defined "unbanked" households as those without checking 
or savings accounts and "underbanked" households as those that have 
such accounts but also rely on alternative financial services. 

[35] Federal Deposit Insurance Corporation, FDIC National Survey of 
Unbanked and Underbanked Households (Washington, D.C.: December 2009), 
p. 16-17. 

[36] Stookey, Inter-American Development Bank, p. 10. 

[37] Federal Deposit Insurance Corporation, p. 25. 

[38] Lutheran Immigration and Refugee Service, p. 9. 

[39] Federal Deposit Insurance Corporation, p. 13. 

[40] Federal Deposit Insurance Corporation, p. 12. Payday loans are 
short-term loans typically extended to consumers who have a checking 
account and can prove that they are employed. Rent-to-own agreements 
are agreements to purchase products, such as furniture and computers, 
under rental-purchase agreements that allow consumers to own the goods 
at the end of the agreement. See FDIC's "Alternative Financial 
Services: A Primer" at [hyperlink, 
http://www.fdic.gov/bank/analytical/quarterly/2009_vol3_1/AltFinServices
primer.html] (accessed Apr. 6, 2010). 

[41] Kenneth Temkin and Noah Sawyer, The Urban Institute, Analysis of 
Alternative Financial Service Providers, prepared for the Fannie Mae 
Foundation (Washington, D.C.: 2004). 

[42] Lutheran Immigration and Refugee Service, p. 11. 

[43] Lutheran Immigration and Refugee Service, p. 11. 

[44] Appleseed, Expanding and Improving Financial Services for Low-and 
Moderate-Income Immigrant Communities: Next Steps, p. 8. 

[45] Press Release, "Federal Trade Commission Protecting America's 
Consumers, FTC Announces New Successes in Campaign to Stop Fraud 
Targeting Hispanics" (Sept. 27, 2006), [hyperlink, 
http://www.ftc.gov/opa/2006/09/nyworkshop.shtm] (accessed Oct. 27, 
2009). 

[46] The 2006-2008 American Community Survey estimates are based on 
data collected between January 2006 and December 2008 for selected 
geographic areas with populations of 20,000 or greater. These 
estimates represent average characteristics over the 3-year period of 
time and have larger sample sizes than 1-year estimates. For 
additional information on the 2006-2008 American Community Survey data 
or the 2000 U.S. Census data, see [hyperlink, 
http://factfinder.census.gov/home/saff/main.html?_lang=en]. 

[47] Executive Order 13166, Improving Access to Services for Persons 
with Limited English Proficiency, which was signed by President 
Clinton in 2000, sought to clarify the responsibilities of federal 
agencies and their grant recipients under Title VI of the Civil Rights 
Act of 1964 to make their programs and activities accessible to 
populations with limited English proficiency. The order required 
federal agencies to issue guidance to their funding recipients to 
avoid discriminating on the basis of national origin. Exec. Order No. 
13166, 65 Fed. Reg. 50121 (Aug. 11, 2000). 

[End of section] 

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